Wainwright v. State
The Florida Supreme Court affirmed summary denial of a death-warrant defendant's eighth successive postconviction motion, which raised an Erlinger v. United States Sixth Amendment claim regarding the prior-violent-felony aggravator, a newly discovered evidence claim about his father's Vietnam-era toxin exposure, and a Brady claim about a jailhouse informant's expectation of a benefit. The Court held the Erlinger claim was procedurally barred as previously raised and rejected, and that even if Erlinger announced a new rule, it does not apply retroactively under Florida's Witt/Linkletter framework. The Court also rejected the newly discovered evidence and Brady claims on the merits and denied the stay of execution.
Key facts
- Wainwright, a death-row inmate, filed his eighth successive postconviction motion raising an Erlinger claim about the prior-violent-felony aggravator, a newly discovered evidence claim based on his father's Vietnam-era toxin exposure, and a Brady claim regarding a jailhouse informant's alleged expectation of benefit.
- The trial court summarily denied the motion, and Wainwright appealed to the Florida Supreme Court seeking to stay his execution.
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Why it matters
This is the first Florida Supreme Court opinion to address whether Erlinger v. United States (2024) applies retroactively to final capital sentences, and it forecloses that argument under both Florida's Witt/Linkletter… — full analysis with a trial
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