Derrick v. State
The Florida Supreme Court affirmed denial of capital postconviction relief on successive 3.851 motions alleging newly discovered evidence that a deceased third party, Keesling, confessed to the murder for which Derrick was sentenced to death. The Court held the hearsay statements failed Florida's statement-against-penal-interest exception because they were largely boastful/braggadocio in a 'lawless' community culture and were insufficiently corroborated, and separately held Chambers v. Mississippi is inapplicable where Florida law already recognizes a statement-against-interest hearsay exception.
Key facts
- Derrick was sentenced to death and filed successive postconviction motions under Florida Rule of Criminal Procedure 3.851 based on newly discovered evidence that a deceased third party, Keesling, allegedly confessed to committing the murder for which Derrick was convicted.
- The newly discovered evidence consisted of hearsay statements in which Keesling purportedly admitted to the murder, made in a community context that valorized violence and 'outlaw' status, with limited independent corroboration.
- +2 more key facts with a free trial
Why it matters
This opinion gives capital and non-capital postconviction practitioners a detailed, fact-rich template for how Florida courts evaluate third-party confession/newly-discovered-evidence claims under the… — full analysis with a trial
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