Brown v. State
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The Supreme Court affirmed the decision of the circuit court denying Tina Lasonya Brown's motion to vacate her conviction of first-degree murder and sentence of death under Fla. R. Crim. P. 3.851 and denied Brown's petition for a writ of habeas corpus, holding that Brown was not entitled to relief.
As to Brown's postconviction appeal, the Supreme Court held (1) the circuit court did not err in denying Brown's allegations of ineffective assistance of counsel in some respects but erred in denying Brown's allegations of ineffective assistance of counsel in other respects; (2) there was no reasonable probability that bur for trial counsel's deficiencies, individually or cumulatively, the outcome would have been different; (3) the circuit court did not err in denying Brown's claim of newly discovered evidence; and (4) the circuit court did not err in summarily denying Brown's claim that she was not entitled to relief from her death sentence under Hurst v. Florida, 136 S. Ct. 616 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016). As to Brown's habeas petition, the Supreme Court held that appellate counsel was not ineffective on direct appeal.
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