James Aren Duckett v. State of Florida

── James Aren Duckett v. State of Florida ── Court: Supreme Court of Florida Date: April 30, 2026 Category: General Supreme Court of Florida ____________ No. SC2026-0528 ____________ JAMES AREN DUCKETT, Appellant, vs. STATE OF FLORIDA, Appellee. April 30, 2026 PER CURIAM. James Aren Duckett is a prisoner under sentence of death whose execution has been stayed. In this case, he appeals the circuit court’s order denying his request to be provided the underlying DNA testing data necessary for an analysis and opinion by a qualified bioinformaticist. That data was generated by a private laboratory that tested a DNA sample relevant to Duckett’s guilt or innocence. Duckett also appeals the circuit court’s denial of his demands for public records in which he sought the testing data as well as information pertaining to the private laboratory’s testing process and protocols. 1 For the reasons that follow, we reverse the circuit court’s denial of Duckett’s request for the underlying DNA testing data. 2 However, we affirm the court’s denial of his public records demands insofar as they sought information regarding the testing process and protocols. Consistent with these holdings, we remand for the underlying testing data to be provided for a statistical analysis, as directed by the Florida Department of Law Enforcement (FDLE). Further, if a dispute arises regarding the extent of the data necessary for analysis, the circuit court shall hold an evidentiary hearing to resolve the dispute. I On February 27, 2026, Governor Ron DeSantis signed a warrant scheduling Duckett’s execution for March 31, 2026. 1. As explained in greater detail below, we have jurisdiction. See art. V, § 3(b)(1), Fla. Const.; § 925.11(3)(a), Fla. Stat. (2025); see also Fla. R. Crim. P. 3.853(f). 2. To the extent Duckett’s public records demands also sought the testing data, we decline to address whether the circuit court abused its discretion in denying the production of such records. Our opinion today renders moot any dispute over the correctness of the circuit court’s ruling in this respect. -2- Following issuance of the death warrant, Duckett filed a motion, which he later amended, seeking postconviction DNA testing under section 925.11, Florida Statutes, and Florida Rule of Criminal Procedure 3.853. The sample he wanted tested was a 1987 swab from the victim’s underwear mounted on a slide (called “Q-6(3)”), which had continuously been in the State’s possession. The swab contained a small number of sperm heads. Duckett contended that DNA testing would show that the sperm was not his, meaning that someone else committed the murder and he is actually innocent. Over two decades ago, during Duckett’s initial postconviction proceedings, we were informed that certain items of clothing introduced into evidence could possibly be tested for DNA, including Q-6(3). Duckett v. State, 918 So. 2d 224, 230 (Fla. 2005). We relinquished jurisdiction to the circuit court to allow for determination of “whether there in fact existed clothing that could be tested for DNA.” Id. On remand, the examiner for FDLE determined that because Q-6(3) had deteriorated and contained too few sperm heads, the DNA testing methods then available would not have produced any conclusive results. Id. The examiner added that any attempt to test the sample would have destroyed it. Id. -3- Outside agencies confirmed the FDLE examiner’s concerns. Thus, no testing was performed on Q-6(3). Id. Noting these background facts, Duckett argued in his rule 3.853 motion that Q-6(3) should be tested using Single Nucleotide Polymorphism (SNP), a technology that allows for more reliable DNA testing of small,