William F. Roberts v. State of Florida

Summary

The Florida Supreme Court affirmed William Roberts' first-degree murder conviction and death sentence for the 2017 killing of Elizabeth Hellstrom, whose body was found in the trunk of her car. The court held the trial court did not abuse its discretion in admitting Williams rule evidence of prior threats and violence, in rejecting the statutory mitigator of substantially impaired capacity to conform conduct, and in allowing the presentence investigation and Dr. Prichard's testimony as rebuttal to mitigation rather than nonstatutory aggravation. It rejected facial Eighth and Fourteenth Amendment challenges to capital punishment generally and to Florida's narrowing procedures as foreclosed by United States Supreme Court precedent. Finally, it upheld the nunc pro tunc competency determination, clarifying that retrospective competency hearings turn on a case-by-case 'meaningfulness' inquiry rather than bright-line evidentiary rules, and concluding that the trial judge's firsthand observations and three expert analyses supplied competent, substantial evidence.