Clark v. State

Citations: 613 So. 2d 412; 1992 WL 381750Docket: 77553

Court: Supreme Court of Florida; December 23, 1992; Florida; State Supreme Court

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Ronald Wayne Clark, Jr. appeals his conviction for first-degree murder and his death sentence, which the Supreme Court of Florida affirmed. The case arose from events on January 13, 1990, when two teenagers discovered incriminating items linked to victim Ronald Willis in Duval County. Willis' ex-wife, after being alerted to his disappearance, found his truck at a motel, where Clark attempted to take the keys from her. Witnesses identified Clark and his accomplice, John Hatch, who were involved in the murder and robbery of Willis. Hatch testified that after hitchhiking with Willis, Clark shot him multiple times and disposed of his body in a ditch and later in the water, using cinder blocks to weigh it down. After fleeing to South Carolina, Clark was arrested and extradited back to Florida. He was indicted for first-degree murder and armed robbery, with Hatch testifying against him in exchange for a reduced sentence. Clark claimed Hatch was the actual killer. The jury convicted him of armed robbery and felony murder. During sentencing, Clark refused to present mitigating evidence, leading the jury to recommend the death penalty, which the court imposed against the defense's argument for life imprisonment.

Clark does not contest the evidence supporting his first-degree murder conviction, which is affirmed. He argues that the trial court erred by allowing him to waive the presentation of mitigating evidence, citing precedents that permit defendants to refuse participation in sentencing proceedings. Despite Clark's claims, a previous case (Klokoc v. State) does not apply here. During the penalty phase, Clark's counsel indicated that he chose not to present mitigating evidence, despite having access to mental health expert testimonies. Clark explicitly stated he did not want the jury to know anything, demonstrating his understanding of the implications of his decision. 

Although Clark's counsel requested consideration of various mitigating factors, including Clark's age and disparities in sentencing compared to another defendant, the jury recommended the death penalty based on three aggravating factors: a prior violent felony conviction, felony murder during a robbery, and pecuniary gain. The trial court instructed that the second and third aggravators should be merged. At sentencing, the court found all three aggravators valid and no mitigators. Clark contends that the court erred by treating felony murder and pecuniary gain as separate aggravators, but any potential error is deemed harmless since the court would have imposed the death sentence based on the remaining valid aggravators. The court’s decision was upheld as there is no evidence that any alleged double consideration influenced the sentence.

Clark contends that the trial court improperly disregarded mitigating evidence and failed to establish several mitigators. However, the court is shown to have considered the mitigating evidence, including psychiatric reports, and concluded that no mitigators were applicable. The decision is supported by competent, substantial evidence indicating the appropriateness of Clark's death sentence. During the penalty phase, testimony from a detective regarding Clark's prior first-degree murder conviction was presented, which Clark claims was inadmissible hearsay that he could not effectively rebut. Florida Statutes § 921.141(1) permits hearsay in penalty proceedings if the defendant can rebut it; Clark was given this opportunity, and his inability to challenge the testimony does not render it inadmissible. No abuse of discretion by the trial court is demonstrated. Clark also argues that his death sentence is disproportionate, but the presence of two valid aggravators, including a prior murder conviction and the absence of mitigators, supports the sentence's proportionality. The cases he cites for comparison are distinguished, affirming that his death sentence aligns with precedents where similar circumstances warranted such a sentence. Consequently, Clark's conviction for first-degree murder and death sentence are affirmed, with concurrence from several justices, including Chief Justice Barkett, who, while concurring, reiterates her stance on the issue of mitigating evidence as previously expressed.