Figueroa-Sanabria v. State
In a capital direct appeal, the Florida Supreme Court affirmed Figueroa-Sanabria's first-degree murder convictions, finding no reversible error in the denial of his motions for new counsel and holding that any error in admitting warrantless historical CSLI evidence (obtained pre-Carpenter) was harmless given overwhelming DNA and other evidence. However, the Court vacated his death sentences and remanded for a new penalty phase, holding that the trial court committed fundamental error by forcing him to choose between accepting counsel (who would present mitigation against his wishes) or proceeding pro se without any mitigation — a choice the court found unconstitutional because a defendant's right to control mitigation presentation does not depend on waiving counsel.
Key facts
- Figueroa-Sanabria was convicted of first-degree murder and sentenced to death in the trial court.
- On direct appeal, the Florida Supreme Court affirmed the convictions but vacated the death sentences and remanded for a new penalty phase.
- +2 more key facts with a free trial
Why it matters
This opinion is highly significant for capital and non-capital criminal practitioners alike because it establishes that trial courts cannot force defendants to choose between retaining counsel and waiving their right to… — full analysis with a trial
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