WILLIAM REAVES
v.
STATE OF FLORIDA & WILLIAM REAVES V. SECRETARY, DEPARTMENT OF CORRECTIONS

Fla. | 2026-10-14
Nos. SC2026-1512 & SC2026-1519
Per Curiam, Couriel, C.J., Muñiz, J., Grosshans, J., Francis, J., Barrios, J., Tanenbaum, J., Labarga, J., Norman, J.
2026 FL 13653 Florida Supreme Court (2026)

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Holding

A capital defendant has no constitutional entitlement to records relating to clemency proceedings, no constitutional right to effective assistance of clemency counsel, and cannot circumvent procedural bars through a habeas petition seeking cumulative review of alleged errors spanning forty years.


Headnotes

[1] A capital defendant has no constitutional entitlement to records relating to clemency proceedings or to effective assistance of clemency counsel, and the executive branch…

[2] A postconviction claim challenging the method of execution is untimely under Florida Rule of Criminal Procedure 3.851(d) when the facts underlying the claim were known or…

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Key Quotes

“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.”

This establishes that the executive branch has broad discretion over clemency procedures and that courts cannot impose procedural requirements on clemency proceedings.

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Facts & Procedural History

William Reaves shot and killed Deputy Richard Raczkoski in September 1986 during an encounter at a convenience store in Vero Beach. Reaves was convict…

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Opinion of the Court

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.

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) 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

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.

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 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).

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)

(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.

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

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

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).

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.


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