In Valle v. Sec. for Dep’t of Corrections, No. 05-15724 (Aug. 11, 2006), the Court affirmed the denial of habeas relief to a Florida inmate sentenced to death for a 1978 murder of a Coral Gables police officer.
Valle claimed that counsel was ineffective because he presented evidence that Valle had been a "model" prisoner, which opened the door for the State to show that he twice tried to escape from prison. The Court found that Valle failed to meet the "prejudice" prong of an ineffectiveness claim.
The Court also rejected Valle’s Batson claim, noting that the prosecutor’s reasons for dismissing black jurors were race neutral, that two black jurors served on the jury, and that Valle himself was not black.
The Court also rejected the claim that his confession was obtained in violation of his Miranda rights, agreeing with the state courts that Valle had not unequivocally invoked his right to remain silent when he told police that he had an attorney who had advised him not to speak to anybody.
Finally, the Court agreed with the Florida Supreme Court that Valle could not prevail on his claim that petit and grand juries in Miami-Dade underrepresented Latin Americans in the relevant time period, because Latin Americans encompass people from too many different backgrounds to constitute a cognizable class for equal protection analysis.
