Eleventh Circuit Court of Appeals - Published Opinions

Friday, December 03, 2010

Puatti: Joint Penalty Phase Was Appropriate

In Puiatti v. McNeil, No. 09-15514 (Nov. 29, 2010), the Court denied habeas relief to a Florida death row inmate convicted of a 1983 murder.

The Court rejected the argument that Puiatti was denied an individualized sentencing determination because the jury considered whether to impose a death sentence on him along with his co-defendant. The Court noted that Puiatti and his co-defendant presented “similar” mitigation theories. The Court added that in this case a joint penalty phase was “particularly appropriate” because the defendants committed the murder together.