Reaves v. State; Reaves v. Secretary, Department of Corrections · Nos. SC2026-1512 and SC2026-1519 (Fla.) · Decided October 14, 2026
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The Florida Supreme Court has affirmed the circuit court’s summary denial of William Reaves’ successive postconviction motion, denied his petition for a writ of habeas corpus, and declined to stay his execution. Reaves was sentenced to death for the 1986 killing of Deputy Richard Raczkoski. The Court said no motion for rehearing will be considered and the mandate shall issue immediately.
What Happened
According to the opinion, Deputy Raczkoski was dispatched to a Vero Beach convenience store in September 1986 after Reaves placed a 911 call from the store’s pay phone. A firearm dropped from Reaves’ shorts during their conversation, and after a scuffle Reaves regained control of it and shot the deputy in the back four times. A jury convicted Reaves of first-degree premeditated murder and he was sentenced to death. The Court reversed that first conviction because the prosecutor had a conflict of interest, Reaves v. State, 574 So. 2d 105 (Fla. 1991). At the retrial, a jury again convicted, recommended death by a 10-to-2 vote, and the circuit court imposed the sentence, which the Court affirmed in Reaves v. State, 639 So. 2d 1 (Fla. 1994). The U.S. Supreme Court denied review in 1994, and the Court noted Reaves has unsuccessfully pursued collateral relief in state and federal court since.
On September 18, 2026, Governor DeSantis signed Reaves’ death warrant. Reaves sought public records from several state agencies, and his requests were denied. He then filed a successive postconviction motion raising three claims: a challenge to the clemency process, a challenge to Florida’s three-drug lethal-injection protocol, and newly discovered evidence of police corruption connected to a State witness. After a Huff hearing, the circuit court summarily denied all claims. On appeal Reaves challenged only the clemency and method-of-execution rulings, and he also filed a habeas petition.
What the Court Held
The Court reviewed the summary denial de novo. On clemency, Reaves argued that he was not provided records or filings from his clemency proceeding, that his clemency counsel was deficient, and that his hearing difficulties could have affected his ability to participate. The Court acknowledged that its precedent, drawing on Justice O’Connor’s concurrence in Ohio Adult Parole Authority v. Woodard, recognizes that “some minimal procedural safeguards apply to clemency procedures,” but noted that its cases emphasize “the unlimited discretion vested solely in the executive branch” over whether to grant clemency and over its procedures, that it has rejected the argument that a capital defendant is entitled to records relating to clemency, and that its precedent does not recognize a constitutional right to the effective assistance of clemency counsel. It called Reaves’ hearing-loss argument speculation and held the clemency claim failed on the merits.
On the method-of-execution claim, the Court held it untimely under Florida Rule of Criminal Procedure 3.851(d), which generally requires claims to be raised within one year of the judgment and sentence becoming final; Reaves’ sentence became final in 1994. His reliance on newly discovered facts, his hearing loss and autopsies of executed inmates from 2017 to 2026, failed because those circumstances “were known or knowable to Reaves many years before he raised the current claim.” The claim was also procedurally barred, and failed on the merits because the Court has upheld Florida’s current three-drug protocol against facial and as-applied challenges.
On habeas, the Court described Reaves’ single claim as a request for cumulative review of the roughly forty-year history of the case, “unencumbered by any procedural bars,” based on the concept of manifest injustice. It said it has rejected similarly broad habeas claims and refused to allow petitioners to circumvent procedural bars, citing Duckett v. State, 435 So. 3d 55, 61 (Fla. 2026). The Court affirmed the circuit court’s order, denied the petition, and declined to stay the execution or grant oral argument. Chief Justice Couriel and Justices Muñiz, Grosshans, Francis, Barrios, and Tanenbaum concurred, and Justice Labarga concurred in the result.
The Opinion
Download the full opinion (PDF)
| Court | Florida Supreme Court |
| Case Nos. | SC2026-1512 and SC2026-1519 |
| Lower Court | Circuit Court, Indian River County (Judge Anastasia M. Norman) |
| Opinion by | Per curiam (Justice Labarga concurring in result) |
| Decided | October 14, 2026 |
| Result | Circuit court order affirmed; habeas petition denied; stay denied |