Background
In the late evening of December 18, 2017, William Roberts sent text messages to a friend indicating his girlfriend, Elizabeth Hellstrom, had become unresponsive but he had “brought her back.” The following day, Roberts revealed to the same friend that Elizabeth was dead and that her body was in the trunk of her Toyota Camry, which he planned to blow up with a propane tank as part of a suicide attempt. Law enforcement located the camper the couple shared — finding blood evidence and stripped bedding — and subsequently discovered Elizabeth’s naked body wrapped in a mattress pad and tarp in the car’s trunk. Roberts was indicted for first-degree murder in February 2018, and the State filed notice of intent to seek the death penalty based on two statutory aggravators: a prior violent felony conviction and the especially heinous, atrocious, or cruel (HAC) nature of the murder.
Roberts waived his right to a jury trial and elected a bench trial. After the trial court found him guilty of first-degree premeditated murder, Roberts also waived his right to present mitigating evidence and his right to an advisory jury recommendation during the penalty phase. The trial court nonetheless ordered a Pre-Sentence Investigation, conducted a Spencer hearing, and on July 28, 2022, sentenced Roberts to death, giving great weight to both statutory aggravators. On initial appeal, the Florida Supreme Court remanded for a nunc pro tunc competency determination after Roberts claimed his due process rights were violated by the absence of a competency hearing at trial.
On remand, the circuit court held a competency hearing in September 2024. Roberts refused to attend in person or virtually. Four witnesses — including the retired trial judge and three forensic experts — testified that Roberts was competent at the time of trial based on his behavior, pro se filings, psychological assessments, and educational achievements while in custody. The circuit court found Roberts competent, and the matter returned to the Florida Supreme Court on supplemental briefing.
The Court’s Holding
The Florida Supreme Court affirmed Roberts’ conviction and death sentence in full, rejecting all claims of trial court error. On the Williams rule issue, the court held that Roberts’ trial counsel had conceded below that the collateral crime evidence — prior threats and acts of violence against the victim — was admissible, rendering any contrary argument unpreserved on appeal. The court further found no abuse of discretion in the trial court’s conclusion that the evidence was properly introduced to complete the narrative of the parties’ relationship and did not become an improper feature of the trial. On the penalty phase claims, the court found no abuse of discretion in the trial court’s rejection of the statutory mitigator relating to impaired capacity to conform conduct to the law, noting that the primary defense expert’s testimony was equivocal and did not establish the mitigator by the greater weight of the evidence.
The court rejected Roberts’ constitutional challenges to the death penalty and to Florida’s capital sentencing scheme as foreclosed by U.S. Supreme Court precedent, including Glossip v. Gross and Baze v. Rees, and by the court’s own prior decisions rejecting proportionality-review and narrowing arguments. On the nunc pro tunc competency determination, the court held that no per se rule forbids retrospective competency evaluations and that the proper standard is whether the evaluation was “meaningful” — i.e., whether the quantity and quality of available evidence allowed a determination rising above mere speculation.
Applying that case-by-case standard, the court upheld the nunc pro tunc finding of competency. The retired trial judge who presided over the proceedings testified to his first-hand contemporaneous observations of Roberts. Three forensic experts independently reviewed trial transcripts, pro se pleadings, and psychiatric records and uniformly concluded Roberts was competent. The court found competent, substantial evidence supported the circuit court’s determination and that Roberts was therefore afforded due process.
Key Takeaways
- A defendant cannot argue on appeal that collateral crime evidence was inadmissible where trial counsel expressly conceded its admissibility below; only the “feature of trial” objection was preserved.
- Florida courts apply a case-by-case “meaningfulness” test — not bright-line rules — to determine whether a nunc pro tunc competency evaluation satisfies due process; testimony from the original trial judge combined with multiple expert reviews of contemporaneous records can be sufficient.
- An expert’s equivocal testimony that stops short of establishing a statutory mitigator by the greater weight of the evidence does not compel the sentencing court to find that mitigator, and the trial court retains discretion to reject it.
- Florida’s elimination of comparative proportionality review and a heightened standard for circumstantial-evidence cases does not render the capital sentencing scheme unconstitutional under existing precedent.
Why It Matters
This decision provides important guidance on the procedural requirements for retrospective competency determinations in Florida capital cases. By reaffirming the “meaningfulness” standard and rejecting any bright-line evidentiary rule, the court signals that nunc pro tunc competency hearings can survive due process scrutiny when the trial judge and contemporaneous experts provide substantive, non-speculative testimony — even when the defendant refuses to cooperate with evaluation. Defense practitioners should note that the quality and proximity in time of available witnesses matters more than any single category of evidence.
The decision also reinforces the significance of trial-level concessions in capital cases. Roberts’ inability to challenge the admissibility of the Williams rule evidence on appeal — because counsel had conceded admissibility below — underscores the high stakes of evidentiary strategy at the trial stage. Combined with the court’s reaffirmation of settled constitutional challenges to capital punishment, the ruling leaves little doctrinal opening for similar defendants to obtain relief on the claims presented here.