Background
William Reaves was convicted of premeditated first-degree murder and sentenced to death for shooting Deputy Richard Raczkoski four times in the back in 1986. The Florida Supreme Court reversed his first conviction because of a prosecutorial conflict of interest, but affirmed the conviction and death sentence imposed after his retrial. The sentence became final in 1994, and Reaves subsequently pursued unsuccessful collateral challenges in state and federal court.
After Governor Ron DeSantis signed Reaves’ death warrant in September 2026, Reaves filed a successive motion for postconviction relief under Florida Rule of Criminal Procedure 3.851. He challenged aspects of the clemency process, Florida’s three-drug lethal-injection protocol, and alleged newly discovered evidence concerning police corruption connected to a State witness. The circuit court summarily denied the motion after a Huff hearing. Reaves appealed the rejection of his clemency and execution-method claims and separately petitioned the Florida Supreme Court for habeas relief.
The Court’s Holding
The Florida Supreme Court affirmed the denial of postconviction relief. It held that Reaves’ clemency claim failed on the merits because he had no entitlement to clemency records or constitutionally effective clemency counsel, and his allegation that hearing difficulties might have impaired his participation was speculative. The court emphasized the executive branch’s broad authority over clemency decisions and procedures.
The court held that the lethal-injection claim was untimely and procedurally barred because Reaves’ hearing loss and the cited autopsy evidence were known or discoverable more than one year before he asserted the claim. It also rejected the claim on the merits under precedent upholding Florida’s three-drug protocol against comparable facial and as-applied challenges. Finally, the court denied habeas relief, refusing to conduct the procedurally unrestricted cumulative review Reaves requested under a manifest-injustice theory.
The court declined to stay the execution or grant oral argument, directed the mandate to issue immediately, and stated that no rehearing motion would be considered.
Key Takeaways
- A death warrant does not revive postconviction claims based on facts that were known or discoverable years earlier.
- Florida precedent does not recognize an entitlement to clemency records or a constitutional right to effective assistance of clemency counsel.
- A habeas petition invoking cumulative error or manifest injustice cannot be used to bypass applicable procedural bars.
Why It Matters
The decision reinforces the strict timeliness and procedural limits governing successive capital postconviction claims in Florida. It also confirms the court’s continued reliance on precedent rejecting constitutional challenges to Florida’s three-drug lethal-injection protocol and limiting judicial review of executive clemency procedures.
For capital practitioners, the ruling underscores that claims based on newly discovered facts must be brought within one year after those facts become discoverable through due diligence, even when an execution warrant has not yet been signed.