Craven v. State / Craven v. Secretary, Department of Corrections
The Florida Supreme Court affirmed the denial of a death-row inmate's initial and successive postconviction motions and denied his habeas petition, rejecting claims including ineffective assistance during jury selection and penalty-phase mitigation investigation, a Giglio/Napue claim about his age at a childhood foster placement, and newly discovered evidence of a seizure disorder. The Court applied the recently decided U.S. Supreme Court case Glossip v. Oklahoma (2025) to articulate the Napue materiality standard, and reaffirmed that postconviction relief cannot rest on cumulative mitigation evidence or on relitigating direct-appeal claims under a different label.
Key facts
- Craven, a death-row inmate, filed initial and successive postconviction motions and a habeas petition raising claims of ineffective assistance of counsel during jury selection and penalty-phase mitigation investigation, Giglio/Napue violations regarding testimony about his age at a childhood foster placement, and newly discovered evidence of a seizure disorder.
- The trial court denied Craven's postconviction motions, and the Florida Supreme Court affirmed the denial of all relief, including the habeas petition.
- +2 more key facts with a free trial
Why it matters
While fact-intensive and ultimately resulting in affirmance across the board, this opinion is useful to capital and non-capital postconviction practitioners for its restatement and application of several recurring… — full analysis with a trial
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