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William Reaves v. State of Florida & William Reaves v. Secretary, Department of Corrections

2026-10-14

Authorities cited

Opinion

majority opinion

Supreme Court of Florida

No. SC2026-1512

WILLIAM REAVES,

Appellant,

vs.

STATE OF FLORIDA,

Appellee.

No. SC2026-1519

WILLIAM REAVES,

Petitioner,

vs.

SECRETARY, DEPARTMENT OF CORRECTIONS,

Respondent.

October 14, 2026

PER CURIAM.

Forty years ago, William Reaves shot and killed Deputy

Richard Raczkoski. Reaves was sentenced to death for this crime.

After Governor Ron DeSantis signed a warrant calling for Reaves’ death sentence to be carried out, Reaves filed a successive motion

for postconviction relief under rule 3.851 of the Florida Rules of

Criminal Procedure. The circuit court summarily denied the

motion. Reaves now appeals that ruling and separately asks us to

grant a writ of habeas corpus. For the reasons given below, we

affirm the circuit court’s order, deny Reaves’ habeas petition, and

decline to issue a stay. 1

I

Early one morning in September 1986, Deputy Raczkoski was

dispatched to a convenience store in Vero Beach based on a 911

call that Reaves had placed using the store’s pay phone. Upon

arrival, Deputy Raczkoski inquired about any existing warrants on

Reaves.

At some point while the two men were talking, a firearm

dropped from Reaves’ shorts. Deputy Raczkoski reached for the

firearm. However, after a scuffle, Reaves succeeded in regaining

control of it. Deputy Raczkoski then told Reaves to give him the

firearm. Reaves refused. Deputy Raczkoski turned and began to

1. We have jurisdiction. See art. V, § 3(b)(1), (9), Fla. Const.

-2-move away from Reaves. Reaves shot him in the back four times,

emptying the firearm’s clip in the process. Deputy Raczkoski died

later that morning from his gunshot wounds.

Reaves fled the scene and went to the home of his friend,

Eugene Hinton, where he admitted to shooting an officer. Reaves

subsequently left the state and was arrested in Georgia shortly

thereafter. While in custody in Georgia, Reaves confessed to police

that he had killed Deputy Raczkoski, stating that he was on cocaine

and fearful at the time of the shooting.

The State charged Reaves with first-degree murder and sought

the death penalty. Following trial, a jury found Reaves guilty of

first-degree premeditated murder, and the circuit court sentenced

him to death in accordance with the jury’s recommendation.

However, we reversed, finding that the prosecutor had a conflict of

interest. Reaves v. State, 574 So. 2d 105, 107 (Fla. 1991).

At Reaves’ retrial, the State introduced evidence supporting

the facts we recounted above and more. Among other things, the

State presented: (1) Reaves’ detailed confession to police;

(2) Hinton’s prior testimony from Reaves’ first trial (including that

Reaves appeared to have full command of his faculties);

-3-(3) testimony from a witness who both found Deputy Raczkoski on

the ground outside the convenience store and observed an

individual fleeing from the scene who matched Reaves’ description;

and (4) evidence about the firearm Reaves used to shoot Deputy

Raczkoski (i.e., that a separate trigger pull was necessary for each

shot).

Later, during jury instructions, the court informed the jury

that voluntary intoxication could negate the element of

premeditation. However, the jury rejected this defense and found

Reaves guilty of premeditated first-degree murder as charged.

Following the penalty phase, the jury recommended death by

way of a 10-to-2 vote. Agreeing with the jury’s recommendation,

the circuit court sentenced Reaves to death. In its sentencing

order, the circuit court found three aggravating factors and

concluded that they outweighed Reaves’ mitigation, which consisted

of three nonstatutory circumstances. 2

2. The aggravating factors were: (1) Reaves had committed prior violent felonies, (2) Reaves murdered Deputy Raczkoski in order to avoid arrest, and (3) the murder was heinous, atrocious, or cruel (HAC). Reaves v. State, 639 So. 2d 1, 3 n.2, 6 n.11 (Fla. 1994). As for mitigation, the court found that Reaves had received an honorable discharge from the military, had a good reputation up

-4-Reaves appealed. But this time, we affirmed. Reaves v. State,

639 So. 2d 1, 6 (Fla. 1994). Although we found insufficient

evidence of the HAC aggravator, we concluded that the other

aggravators justified the death sentence in light of the relatively

minimal mitigation. Id.

Reaves then petitioned the United States Supreme Court to

review our decision. That request was denied. Reaves v. Florida,

513 U.S. 990 (1994). Reaves’ murder conviction and death

sentence became final at that time. See Fla. R. Crim. P.

3.851(d)(1)(B).

Since then, Reaves has unsuccessfully pursued collateral relief

in both state and federal court. See Reaves v. State, 826 So. 2d 932

(Fla. 2002); Reaves v. Crosby, 837 So. 2d 396 (Fla. 2003); Reaves v.

State, 942 So. 2d 874 (Fla. 2006); Reaves v. State, 27 So. 3d 661

(Fla. 2009); Reaves v. State, 91 So. 3d 782 (Fla. 2012); Reaves v.

State, 241 So. 3d 63 (Fla. 2018); Reaves v. Sec’y, Fla. Dep’t of Corr.,

717 F.3d 886 (11th Cir. 2013); Reaves v. Sec’y, Fla. Dep’t of Corr.,

872 F.3d 1137 (11th Cir. 2017), cert. denied, 585 U.S. 1020 (2018).

to the age of sixteen, and was a considerate son and good sibling. Id. at 3 n.3.

-5-On September 18, 2026, Governor DeSantis signed Reaves’

death warrant. Thereafter, Reaves sought public records from

several state agencies, but his requests were denied. He then filed

the successive postconviction motion mentioned at the outset of

this opinion. In that motion, Reaves raised three claims. The first

challenged various aspects of his clemency process, while another

challenged the method of his execution, i.e., Florida’s three-drug

lethal-injection protocol. Rounding out his claims, Reaves alleged

newly discovered evidence regarding police corruption in connection

with a State witness.

After holding a Huff 3 hearing, the circuit court summarily

denied all of Reaves’ postconviction claims. Reaves now appeals,

arguing that the circuit court committed error in denying his

clemency and method-of-execution claims. He also asks us to issue

a writ of habeas corpus. We begin with Reaves’ appeal.

II

We review the summary denial of successive postconviction

claims de novo. Randolph v. State, 422 So. 3d 166, 172 (Fla.), cert.

3. Huff v. State, 622 So. 2d 982 (Fla. 1993).

-6-denied, 146 S. Ct. 819 (2025). We affirm where the claims are

untimely, procedurally barred, legally insufficient, or refuted by the

record. Sochor v. State, 434 So. 3d 1251, 1254 (Fla.), cert. denied,

No. 26-5061, 2026 WL 2028264 (U.S. July 14, 2026). Applying this

framework, we reject Reaves’ arguments for reversal.

A

In his motion below, Reaves alleged that his clemency

procedures were constitutionally infirm because (1) he was not

provided with records or filings in connection with his clemency

proceeding, (2) his clemency counsel was deficient in various

respects, and (3) his hearing difficulties over the years could have

adversely affected his ability to participate in the clemency

proceeding. The circuit court ruled that Reaves’ clemency claim

was untimely, procedurally barred, and legally insufficient. We

agree that this claim does not warrant relief.

Our precedent acknowledges Justice O’Connor’s concurrence

in Ohio Adult Parole Authority v. Woodard, 523 U.S. 272, 288

(1998), as support for the proposition that “some minimal

procedural safeguards apply to clemency procedures.” See

Rutherford v. State, 940 So. 2d 1112, 1121 n.4 (Fla. 2006)

-7-(emphasis omitted). Even still, our cases have emphasized the

unlimited discretion vested solely in the executive branch, both to

decide whether to grant clemency and to establish the procedures

governing the clemency process. Marek v. State, 14 So. 3d 985, 998

(Fla. 2009); Carroll v. State, 114 So. 3d 883, 888 (Fla. 2013);

Zakrzewski v. State, 415 So. 3d 203, 211 (Fla.), cert. denied, 146 S.

Ct. 57 (2025); see also art. IV, § 8(a), Fla. Const.

In applying these principles, we have rejected the argument

that a capital defendant has any entitlement to records relating to

his clemency proceeding. Randolph, 422 So. 3d at 174; Bates v.

State, 416 So. 3d 312, 321 (Fla.), cert. denied, 146 S. Ct. 66 (2025);

Heath v. State, 426 So. 3d 1253, 1265 (Fla.), cert. denied, No. 25-6746, 2026 WL 363902 (U.S. Feb. 10, 2026).

Moreover, our precedent does not recognize a constitutional

right to the effective assistance of clemency counsel. Lukehart v.

State, 51 Fla. L. Weekly S139, S142 n.13 (Fla. May 27) (“[U]nder

Florida and federal law, a defendant has no constitutional right to

effective collateral counsel.” (quoting Zack v. State, 911 So. 2d 1190,

1203 (Fla. 2005))), cert. denied, 146 S. Ct. 2697 (2026); Barwick v.

State, 361 So. 3d 785, 791 (Fla. 2023) (same); see also Bowles v.

-8-DeSantis, 934 F.3d 1230, 1242 n.8 (11th Cir. 2019) (“[G]iven that

there is no constitutional right to clemency, there is no

constitutional right to effective assistance of counsel in clemency

proceedings.” (citing Coleman v. Thompson, 501 U.S. 722, 752

(1991))); Banks v. Sec’y, Fla. Dep’t. of Corr., 592 F. App’x 771, 773

(11th Cir. 2014) (rejecting argument that clemency counsel’s

ineffectiveness was a basis for challenging Florida’s clemency

process). Thus, we do not find that Reaves’ criticisms of his

clemency counsel offer any meaningful support for his claim.

Additionally, Reaves’ speculation that his hearing issues may

have caused him to miss critical information during the clemency

hearing cannot support relief. See Valle v. State, 70 So. 3d 530,

550 (Fla. 2011) (rejecting claims premised on speculative

allegations).

Accordingly, Reaves’ clemency claim fails on the merits.

B

Reaves also advanced a method-of-execution claim, which the

circuit court rejected on procedural grounds and on the merits. We

agree with the court’s ruling.

Reaves’ claim is untimely under rule 3.851(d). This rule

-9-requires that postconviction claims be raised within one year of the

judgment and sentence becoming final. In this case, Reaves’ death

sentence became final in 1994. Thus, his claim is untimely unless

one of rule 3.851(d)(2)’s timeliness exceptions applies.

Reaves invokes the exception for claims premised on newly

discovered facts, relying on his hearing loss and certain autopsies of

executed inmates spanning from 2017 to 2026. Notably, though,

these circumstances were known or knowable to Reaves many years

before he raised the current claim. Reaves was required to raise his

claim within one year of those facts becoming discoverable through

due diligence. See Randolph, 422 So. 3d at 172 (to meet the

timeliness exception for newly discovered evidence, “the claim must

still be filed within a year of when th[e] facts became discoverable”).

He did not; so his claim is untimely.

Reaves’ claim is also procedurally barred, much for the same

reasons identified above. See id. at 173 (enforcing procedural bar

where claim could have been raised in earlier proceeding, but was

not).

Finally, Reaves’ method-of-execution claim fails on the merits.

We have upheld Florida’s current three-drug protocol against facial

- 10 -and as-applied challenges, including ones comparable to Reaves’.

See Sochor, 434 So. 3d at 1254 (collecting cases). Based on that

precedent, Reaves’ claim cannot succeed.

In sum, Reaves has not demonstrated any basis for reversing

the circuit court. We now turn to his habeas petition.

III

Reaves’ habeas petition contains one claim. In advancing his

claim, Reaves details the roughly forty-year history of his case

(going back to his initial trial); underscores evidence that he deems

favorable to his position; and asserts that errors throughout his

case were “incessant” and “destructive.” Ultimately, Reaves asks us

to conduct some form of cumulative review unencumbered by any

procedural bars and to ultimately award him relief. This claim,

which repeatedly invokes the concept of manifest injustice, does not

justify relief.

We have rejected similarly broad habeas claims and refused to

allow petitioners, like Reaves, to circumvent procedural bars.

See Duckett v. State, 435 So. 3d 55, 61 (Fla. 2026) (rejecting habeas

petitioner’s actual-innocence and cumulative-error claims;

enforcing procedural bars).

- 11 -In short, our precedent forecloses the habeas relief that Reaves

seeks.

IV

For the reasons given above, we affirm the circuit court’s order

denying relief. We also deny Reaves’ habeas petition. In light of

these holdings, we decline to stay Reaves’ execution or grant his

request for oral argument. No motion for rehearing will be

considered. The mandate shall issue immediately.

It is so ordered.

COURIEL, C.J., and MUÑIZ, GROSSHANS, FRANCIS, BARRIOS, and TANENBAUM, JJ., concur.

LABARGA, J., concurs in result.

An Appeal from the Circuit Court in and for Indian River County,

Anastasia M. Norman, Judge

Case No. 311986CF000729AXXXVB

And an Original Proceeding – Habeas Corpus

Suzanne Keffer, Capital Collateral Regional Counsel, Brittney N. Lacy, Assistant Capital Collateral Regional Counsel, and Yiitsodirah Final, Staff Attorney, Office of Capital Collateral Regional Counsel, Southern Region, Fort Lauderdale, Florida,

for Appellant/Petitioner

James Uthmeier, Attorney General, Tallahassee, Florida, Lisa-Marie Lerner, Senior Assistant Attorney General, West Palm Beach, Florida, and Leslie T. Campbell, Senior Assistant Attorney General, West Palm Beach, Florida,

- 12 -for Appellee/Respondent

Marie-Louise Samuels Parmer of Samuels Parmer Law, P.A., Tampa, Florida,

for Amicus Curiae Center for Veteran Criminal Advocacy

- 13 -