Jeffrey G. Hutchinson v. State of Florida

CourtSupreme Court of Florida
DecidedJune 16, 2022
DocketSC21-18
StatusPublished

This text of Jeffrey G. Hutchinson v. State of Florida (Jeffrey G. Hutchinson v. State of Florida) is published on Counsel Stack Legal Research, covering Supreme Court of Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jeffrey G. Hutchinson v. State of Florida, (Fla. 2022).

Opinion

Supreme Court of Florida ____________

No. SC21-18 ____________

JEFFREY G. HUTCHINSON, Appellant,

vs.

STATE OF FLORIDA, Appellee.

June 16, 2022

PER CURIAM.

Jeffrey G. Hutchinson, a prisoner under sentence of death,

appeals the circuit court’s order summarily denying his second

successive motion for postconviction relief, filed under rule 3.851 of

the Florida Rules of Criminal Procedure.1 For the reasons that

follow, we affirm.

I. Background

In 1998, Hutchinson shot and killed his girlfriend, Renee

Flaherty, and her three children: four-year-old Logan, seven-year-

1. We have jurisdiction. See art. V, § 3(b)(1), Fla. Const. old Amanda, and nine-year-old Geoffrey. We have described the

events surrounding the murders as follows:

On the evening of the murders, Hutchinson and Renee argued. Hutchinson packed some of his clothes and guns into his truck, left, and went to a bar . . . [,] arriv[ing] [there] around 8 p.m. Hutchinson told the bartender that “Renee is pissed off at me,” drank one and a half glasses of beer and then left the bar muttering to himself. . . . Approximately forty minutes after Hutchinson left the bar, there was a 911 call from Hutchinson’s home. The caller stated, “I just shot my family.” Two of Hutchinson’s close friends identified the caller’s voice as Hutchinson’s. Hutchinson said to the 911 operator, “there were some guys here.” He told the operator that he did not know how many people were there, he did not know how many had been hurt, and he did not know how they had been injured. Deputies arrived at Hutchinson’s home within ten minutes of the 911 call and found Hutchinson on the ground in the garage with the cordless phone nearby. The phone call was still connected to the 911 operator. Deputies found Renee’s body on the bed in the master bedroom, Amanda’s body on the floor near the bed in the master bedroom, and Logan’s body at the foot of the bed in the master bedroom. Each had been shot once in the head with a shotgun. Deputies found Geoffrey’s body on the floor in the living room between the couch and the coffee table. He had been shot once in the chest and once in the head. The murder weapon, a Mossberg 12-gauge pistol-grip shotgun which belonged to Hutchinson, was found on the kitchen counter. Hutchinson had gunshot residue on his hands. He also had Geoffrey’s body tissue on his leg.

Hutchinson v. State, 882 So. 2d 943, 948 (Fla. 2004).

-2- The State charged Hutchinson with four counts of first-degree

murder. Following trial, a jury found him guilty as charged on all

four counts, and he proceeded to waive a penalty-phase jury.

Ultimately, after the bench penalty phase, the trial court sentenced

Hutchison to death for the murder of each child and imposed a life

sentence for the murder of his girlfriend.

We affirmed Hutchinson’s convictions and sentences, which

became final in 2004, see Fla. R. Crim. P. 3.851(d)(1)(A). Since that

time, Hutchinson has sought postconviction relief in both state and

federal court but has had no success in either forum.

See Hutchinson v. State, 17 So. 3d 696, 704 (Fla. 2009) (affirming

denial of initial postconviction motion); Hutchinson v. State, 243 So.

3d 880, 884 (Fla. 2018) (affirming denial of first successive

postconviction motion).

Hutchinson has now filed his second successive

postconviction motion asserting four claims for relief. All four

claims involve witnesses, Joel and Deanna Adams, who testified at

trial that they recognized Hutchinson’s voice to be that of the 911

caller.

-3- Prior to Hutchinson’s trial, Mr. and Ms. Adams testified before

a federal grand jury regarding their possible involvement in two

bank robberies unrelated to the murders. Relying on this FBI

investigation, Hutchinson’s defense counsel sought to impeach both

witnesses at trial on the theory that each was biased toward the

prosecution in hopes of obtaining favorable treatment from the

State in relation to the unrelated robberies. Partially accepting

defense counsel’s argument, the trial court allowed counsel to cover

this topic when cross-examining Ms. Adams.

More than ten years after Hutchinson’s murder convictions

became final, he submitted a request to the FBI regarding its

investigation into the bank robberies. In his second successive

postconviction motion, he claimed that the records received from

the FBI constituted newly discovered evidence under Jones v. State,

709 So. 2d 512 (Fla. 1998). He further claimed that the State

committed a Brady 2 violation by not disclosing those records to the

defense. In addition, he asserted that the State violated Giglio v.

United States, 405 U.S. 150 (1972), and that a new trial was

2. See Brady v. Maryland, 373 U.S. 83 (1963).

-4- warranted based on cumulative error. According to him, his four

claims were timely as a result of equitable tolling. The circuit court

summarily denied all of Hutchinson’s claims and found equitable

tolling inapplicable to the facts of this case.

This appeal follows.

II. Analysis

Hutchinson argues that the circuit court erred in denying his

postconviction motion without first holding an evidentiary hearing.

We disagree.

“A circuit court should hold an evidentiary hearing on a rule

3.851 motion ‘whenever the movant makes a facially sufficient

claim that requires a factual determination.’ ” Rogers v. State, 327

So. 3d 784, 787 (Fla. 2021) (quoting Pardo v. State, 108 So. 3d 558,

560 (Fla. 2012)).3 In contrast, a circuit court may summarily deny

a claim that is legally insufficient or refuted by the record. Id. at

787-88; McDonald v. State, 296 So. 3d 382, 383 n.2 (Fla. 2020).

With this framework in mind, we now turn to Hutchinson’s claims.

3. “The standard of review here is de novo.” Rogers, 327 So. 3d at 787 n.5.

-5- We first consider Hutchinson’s newly discovered evidence

claim. To be facially sufficient, a claim of newly discovered evidence

must meet the two-part Jones test. We have described that test as

follows:

First, the evidence must not have been known by the trial court, the party, or counsel at the time of trial, and it must appear that the defendant or defense counsel could not have known of it by the use of diligence. Second, the newly discovered evidence must be of such [a] nature that it would probably produce an acquittal on retrial.

Long v. State, 183 So. 3d 342, 345 (Fla. 2016) (quoting Tompkins v.

State, 994 So. 2d 1072, 1086 (Fla. 2008)).

We agree with the circuit court that Hutchinson cannot prevail

on his newly discovered evidence claim. Even before his trial in

2001, Hutchinson knew of the FBI’s investigation of Mr. and Ms.

Adams. Attachments to the second amended postconviction motion

demonstrate that the FBI records were available—upon request to

federal authorities—at least by 2007.

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Related

Brady v. Maryland
373 U.S. 83 (Supreme Court, 1963)
Giglio v. United States
405 U.S. 150 (Supreme Court, 1972)
Hutchinson v. State
17 So. 3d 696 (Supreme Court of Florida, 2009)
Tompkins v. State
994 So. 2d 1072 (Supreme Court of Florida, 2008)
Jones v. State
709 So. 2d 512 (Supreme Court of Florida, 1998)
Hutchinson v. State
882 So. 2d 943 (Supreme Court of Florida, 2004)
Allen v. State
854 So. 2d 1255 (Supreme Court of Florida, 2003)
Robert Joe Long v. State of Florida
183 So. 3d 342 (Supreme Court of Florida, 2016)
Jeffrey Glenn Hutchinson v. State of Florida
243 So. 3d 880 (Supreme Court of Florida, 2018)
Pardo v. State
108 So. 3d 558 (Supreme Court of Florida, 2012)
Diaz v. State
132 So. 3d 93 (Supreme Court of Florida, 2013)

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