Sexton v. State
On appeal from a second capital penalty-phase proceeding (a bench trial after a Hurst remand), the Florida Supreme Court affirmed Sexton's death sentence, rejecting eight claims of error. The Court held it was error, though harmless, for the trial court to call the defendant's own mitigation specialist as a court witness over his objection when he sought to limit mitigation, and that the trial court properly denied additional expert-funding requests (PET scan, out-of-state travel) under the Ake/Rogers particularized-need standard.
Key facts
- Defendant Sexton was resentenced to death in a second capital penalty-phase proceeding (bench trial) after a Hurst remand, and appealed challenging eight claims of error.
- The trial court called defendant's own mitigation specialist as a court witness over his objection, denied funding requests for a PET scan and out-of-state expert travel, took judicial notice of the entire prior trial record, and imposed a death sentence.
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Why it matters
This capital resentencing decision offers useful guidance on two recurring death-penalty issues: the boundaries of a trial court's authority to call a defense mitigation specialist as its own witness (clarifying and… — full analysis with a trial
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