Tanzi v. State; Tanzi v. Secretary, Department of Corrections
In a death-warrant appeal, the Florida Supreme Court affirmed the summary denial of Tanzi's successive postconviction motion and denied his habeas petition, rejecting claims about the compressed warrant litigation schedule, denial of public records requests, an as-applied Eighth Amendment challenge to lethal injection based on obesity/medical conditions, and a challenge to gubernatorial authority over warrant timing. The Court also addressed and rejected a novel argument that Erlinger v. United States (2024) undermines Florida's capital sentencing scheme and the Hurst/Davis line of cases, holding Erlinger inapplicable because it was a direct-appeal ACCA case involving jury findings on an element, unlike Florida's postconviction capital sentencing context.
Key facts
- Tanzi was convicted and sentenced to death; the Florida Supreme Court previously affirmed his conviction and sentence in Tanzi IV.
- After a death warrant was signed, Tanzi filed a successive postconviction motion and habeas petition raising claims about the warrant litigation schedule, public records requests, lethal injection as applied to him based on obesity and medical conditions, and arguing that Erlinger v. United States undermined Florida's capital sentencing scheme.
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Why it matters
This opinion is useful for capital postconviction practitioners because it directly addresses and forecloses the emerging argument that Erlinger v. United States (2024) revives Hurst-type challenges to Florida's capital… — full analysis with a trial
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