Doty v. State
The Florida Supreme Court affirmed summary denial of capital defendant Wayne Doty's initial Rule 3.851 postconviction motion, as well as orders denying his requests for a PET scan/MRI and to interview a venire member. The Court held that Doty's relative-culpability, Giglio, self-representation-competency (Edwards), juror-questioning, and ineffective-assistance claims were all procedurally barred, facially insufficient, and/or conclusively refuted by the record, given Doty's history of knowingly and competently representing himself through two penalty phases.
Key facts
- Wayne Doty, a capital defendant, was convicted and sentenced to death; he filed an initial Rule 3.851 postconviction motion raising claims of relative culpability, Giglio violation, ineffective assistance of standby counsel, juror-questioning error, and competency issues.
- Doty, who represented himself through two penalty phases with standby counsel, sought a PET scan/MRI and requested to interview a venire member as part of his postconviction relief efforts.
- +2 more key facts with a free trial
Why it matters
This opinion is useful primarily as a compilation and reaffirmation of settled capital postconviction procedural bars rather than as new precedent: it confirms Cruz's abandonment of relative-culpability review… — full analysis with a trial
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