Dillbeck v. State; Dillbeck v. Dixon
In a death-warrant case, the Florida Supreme Court affirmed summary denial of Dillbeck's fourth successive postconviction motion and denied his habeas petition. The Court held his claim that ND-PAE is now scientifically equivalent to intellectual disability was both time-barred as newly discovered evidence and, if not framed as newly discovered evidence, not cognizable at all in a successive motion under Carroll v. State; it also rejected his newly discovered evidence claim regarding 1979 witness statements as untimely and insufficient to probably yield a lesser sentence, rejected his Johnson v. Mississippi claim as unripe since his 1979 conviction remains unreversed, and reaffirmed that lengthy death-row incarceration does not violate the Eighth Amendment.
Key facts
- Mark Dillbeck was convicted and sentenced to death; he filed a fourth successive postconviction motion and habeas petition challenging his sentence on the grounds of newly discovered evidence regarding a mental condition (ND-PAE) and prior conviction issues.
- The trial court summarily denied the successive motion, and the Florida Supreme Court affirmed the denial while also denying the habeas petition.
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Why it matters
This decision reinforces several recurring procedural doctrines in Florida capital postconviction practice: it extends Carroll v. State's bar on non-newly-discovered-evidence claims to… — full analysis with a trial
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