Florida Supreme Court affirms denial of Richard Randolph's request for postconviction relief

On Thursday, December 5, as part of its regular release of opinions, the Florida Supreme Court issued its decision in Randolph v. State.

On Thursday, December 5, as part of its regular release of opinions, the Florida Supreme Court issued its decision in Randolph v. State.

Richard Randolph was sentenced to death for crimes that occurred in 1988 following the jury’s recommendation for death by a vote of 8-4.¹ In 1990, on direct appeal, the Florida Supreme Court affirmed his conviction and sentence of death.

In this case, Randolph sought relief based on newly discovered evidence related to his birth parents. Specifically, the opinion explains:

A recent change in New York law allowed Randolph to retrieve his original birth certificate, reunite with his birth mother, and learn additional facts about his birth parents. His birth mother was in fact a 17-year-old high school student when he was born, not a college student. Both his birth parents did indeed graduate from college, however, and both went on to have successful relationships and careers after placing him for adoption. Neither of them appears to have been affected by mental health challenges or substance use disorders. Each of his birth parents would, if called, testify to that effect.

Randolph claims that this information, coupled with testimony from an adoption expert, would probably yield a life sentence. This newly discovered evidence would help his case, he contends, because it would tend to show that he lacked a genetic predisposition to criminal violence, and that a significant contributing factor to his decision-making was the cruelty he suffered as a child from his adoptive parents.

The circuit court summarily denied Randolph’s claim without an evidentiary hearing.

In its opinion, written by Justice Couriel, the Supreme Court affirmed the circuit court’s denial, determining that the newly discovered evidence would not have changed the outcome in Randolph’s case. The Court wrote:

The identity of Randolph’s birth parents, their degree of educational attainment at the time of his birth, and their generally successful lives do not tend to prove or disprove any matter at issue. He therefore cannot show that the evidence he seeks to introduce would yield a less severe sentence. And even if Randolph’s genetic traits were a matter on which the sentencing court had to pass, the fact that his birth parents are from all outward appearances well-adjusted people would not necessarily establish anything about their, or his, inherited traits. See § 90.401, Fla. Stat. (2023).

Had Randolph not been adopted, or adopted by different people, it well may be that the environmental factors that contributed to his development would have been different. But Dr. Krop already testified that the abuse Randolph suffered from his adoptive parents contributed to or reinforced his personality disorder. Dr. Krop also testified about the increased likelihood of strong psychological well-being for individuals raised by stable and loving parents compared to those raised by abusive ones.

The decision was unanimous.

The Opinion can be accessed on the Court’s website here.

1. Randolph v. State, 562 So. 2d 331, 334 (Fla. 1990).