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Oats v. Jones

Supreme Court of Florida

May 25, 2017

SONNY BOY OATS, JR., Petitioner,
v.
JULIE L. JONES, etc., Respondent.

         NOT FINAL UNTIL TIME EXPIRES TO FILE REHEARING MOTION, AND IF FILED, DETERMINED.

         Original Proceeding - Habeas Corpus

          Martin J. McClain, Special Assistant Capital Collateral Regional Counsel, and Nicole M. Noël, Assistant Capital Collateral Regional Counsel, Southern Region, Fort Lauderdale, Florida, for Petitioner

          Pamela Jo Bondi, Attorney General, Tallahassee, Florida; and Vivian Singleton, Assistant Attorney General, Daytona Beach, Florida, for Respondent

          PER CURIAM

         Sonny Boy Oats, Jr., was tried and convicted for the December 1979 robbery of a convenience store and first-degree murder of the store clerk. Oats v. State, 181 So.3d 457, 460 (Fla. 2015). This Court affirmed Oats' conviction on direct appeal but held that the trial court erroneously found three aggravating factors and remanded to the trial court for entry of a new sentencing order. Oats v. State, 446 So.2d 90, 95-96 (Fla. 1984). On remand, the trial court reweighed the valid aggravating factors and again imposed the death penalty, which this Court then affirmed. Oats v. State, 472 So.2d 1143, 1145 (Fla.), cert. denied, 474 U.S. 865 (1985). This Court later affirmed the trial court's denial of Oats' initial motion for postconviction relief and denied his petition for a writ of habeas corpus. Oats v. Dugger, 638 So.2d 20, 20 (Fla. 1994).

         In late 2015, pursuant to the United States Supreme Court's decision in Hall v. Florida, 134 S.Ct. 1986 (2014), this Court remanded Oats' case back to the circuit court for a new intellectual disability evidentiary hearing. Oats, 181 So.3d at 471.[1] Following this Court's opinion in Hurst v. State (Hurst), 202 So.3d 40 (Fla. 2016), cert. denied, No. 16-998 (U.S. May 22, 2017), on October 28, 2016, Oats filed a postconviction motion in the circuit court seeking relief under Hurst, which the circuit court held in abeyance pending the evidentiary hearing on Oats' Hall claim.

         On January 17, 2017, Oats filed the current petition for a writ of habeas corpus and additionally filed a motion to stay the circuit court proceedings (on remand from this Court's 2015 decision).[2] In his petition, Oats contends that (1) he is entitled to have his death sentence vacated pursuant to Hurst, and (2) regardless, Hurst applies to cases involving Hall claims, like his, because the determination of whether a defendant is intellectually disabled is a fact that must be found by the jury. For reasons more fully explained below, we conclude that Oats is not entitled to relief. Accordingly, we deny Oats' petition.

         ANALYSIS

         As to Oats' first claim, we conclude that Oats is not entitled to Hurst relief because Hurst does not apply retroactively to Oats' sentence, which became final in 1985. See Asay v. State, 210 So.3d 1 (Fla. 2016), petition for cert. filed, No. 16-9033 (U.S. Apr. 29, 2017); see also Oats, 472 So.2d 1143.

         Next, we address Oats' claim that the United States Supreme Court's decision in Hurst v. Florida and this Court's decision in Hurst require that the jury, rather than the trial judge, determine intellectual disability. In granting Oats a new hearing on his claim of intellectual disability, we concluded:

[T]he circuit court erred in determining that Oats failed to establish onset of his intellectual disability prior to the age of 18. The evidence presented to the circuit court in fact strongly leads to the conclusion that Oats established both his low IQ and onset of an intellectual disability prior to the age of 18. However, because the circuit court did not analyze the remaining prongs, and because neither the circuit court nor the parties and their experts had the benefit of Hall, we remand for further proceedings consistent with this opinion, including providing the parties with an opportunity to present additional evidence at an evidentiary hearing to enable a full reevaluation of whether Oats is intellectually disabled.

Oats, 181 So.3d at 471. Our instruction was clear that the new intellectual disability hearing should be held before the trial court.

         Pursuant to section 921.141, Florida Statutes (2016), once a defendant is convicted of first-degree murder, the minimum sentence is life imprisonment without parole. See § 921.141(3), Fla. Stat. (2016); Hurst, 202 So.3d at 51. The trial then proceeds to the penalty phase where the jury ultimately determines whether the defendant ...


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