FLORIDA SUPREME COURT AFFIRMS DEATH SENTENCE OF WOMAN WHO SET VICTIM ON FIRE

The Supreme Court of Florida on Thursday affirmed a lower court’s denial of a successive motion for postconviction relief and a motion for public records filed by death row inmate Tina Lasonya Brown.

Justice Renatha Francis delivered the opinion of the court, concluding that the new evidence presented by Brown’s defense—primarily the recantation of a key trial witness—was neither credible nor sufficient to likely alter her sentence.

Brown was convicted of first-degree murder and sentenced to death for the 2010 killing of Audreanna Zimmerman. According to court records, Brown, her 16-year-old daughter Britnee Miller, and Heather Lee kidnapped Zimmerman, beat her with a crowbar, stunned her with a stun gun, and set her on fire.

Zimmerman died from her injuries 16 days after the attack. Lee later accepted a plea deal to second-degree murder and testified against Brown.

In August 2022, Brown filed a successive postconviction motion based on newly discovered evidence. The motion centered on an affidavit from Corie Doyle, Brown’s former jail cellmate who had corroborated Lee’s testimony during the original trial.

In the affidavit, Doyle claimed that Lee had threatened her into lying on the stand and that Lee had confessed to a larger role in the attack. Brown also submitted testimony from several mitigation experts detailing childhood trauma and head injuries, arguing this evidence warranted a new penalty phase.

During a subsequent evidentiary hearing, Doyle contradicted her original trial testimony, stating that Brown never spoke to her about the case while incarcerated. However, under cross-examination, Doyle testified that she did not know she was signing an affidavit for a defense investigator, claimed she was pressured into making the statement, and admitted she could not remember everything due to extensive history with drug abuse.

The postconviction court denied Brown’s motion, ruling that the claim was untimely and that Doyle’s recantation lacked credibility.

The Supreme Court disagreed with the lower court regarding the timeliness of Doyle’s recantation, noting that a recantation is considered discovered when the witness chooses to recant, which occurred in December 2021. However, the high court upheld the finding that Doyle’s new testimony was unreliable, citing her contradictory statements, her attempts to disclaim the affidavit, and an “antagonistic” demeanor during the hearing.

The court further determined that even if the new evidence and expert mitigation were considered, it would not probably yield a life sentence instead of death. The opinion noted that independent evidence, including Brown’s DNA on the stun gun, eyewitness testimony from a teenager present during the initial assault, and Zimmerman’s dying declarations to emergency responders, established Brown as the primary aggressor.

The court also affirmed the denial of Brown’s request for public records concerning jailhouse phone calls between Lee and Doyle, finding the issue immaterial given the overwhelming evidence of guilt and the severe nature of the crime.

Chief Justice Muñiz and Justices Couriel, Labarga, Grosshans, and Sasso concurred with the decision. Justice Tanenbaum did not participate in the ruling.

READ: Florida Supreme Court Shuts Down Death Row Inmate’s Bid For New Trial

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