Whether trial counsel has an obligation to conduct a comprehensive mitigation investigation

QUESTIONS PRESENTED 1. Whether trial counsel has an obligation to conduct a comprehensive mitigation investigation when clear red flags suggest compelling mitigation, including physical, sexual, and emotional abuse, neglect, addiction, and mental health problems? 2. Whether a capital petitioner must demonstrate new mitigating factors in postconviction proceedings in order to establish prejudice under Strickland v. Washington, 466 US. 668 (1984), or can compelling statutory and non-statutory mitigating evidence that strengthens, corroborates and confirms evidence presented at a capital penalty phase and impacts the sentencing calculus establish prejudice? 3. Whether the strengthening of mental health evidence due to increased precision of a diagnosis in postconviction that decreases the weight of the aggravating circumstances while increasing the weight of mitigating factors must be considered in the Strickland prejudice analysis? 4. Whether the Eleventh Circuit misapplied the standard for a certificate of appealability by disregarding judicial disagreement on the retroactivity of Hurst v. Florida, 136 S.Ct. 616 (2016), and/or by addressing the substance of the claim? i NOTICE OF RELATED CASES Per Supreme Court Rule 14.1 (b)(ii), the following cases relate to this petition: Underlying Tvial: Circuit Court of Palm Beach County, Florida State of Florida v. Ronald Knight, Case No. 97-5175CF A02 Judgement Entered May 29, 1998 Appellate Proceedings: Florida Supreme Court (Case No. 93,473) Knight v. State, 770 So. 2d 663 (Fla. 2000) Conviction and Sentence Affirmed: November 2, 2000 Petition for Writ of Certiorari: United States Supreme Court Knight v. Florida, 532 U.S. 1011 (2001) Certiorari Denied: April 30, 2001 Initial Postconviction Proceedings: Circuit Court of Palm Beach County, Florida State of Florida v. Ronald Knight, Case No. 97-5175CF A02 Judgement Entered February 5, 2013 (denying motion) Appellate Proceedings: Florida Supreme Court (Case No. SC13-820) Knight v. State, 211 So. 3d 663 (Fla. 2016) Affirmed: December 15, 2016 Petition for Writ of Habeas Corpus: Florida Supreme Court (Case No. SC14-567) Knight v. State, 211 So. 3d 663 (Fla. 2016) Denied: December 15, 2016 Successive Petition for Writ of Habeas Corpus: Florida Supreme Court (Case No. SC17-2021) Knight v. Jones, 2018 WL. 580765 (Fla.) Denied January 29, 2018 Appellate Proceedings: Eleventh Circuit Court of Appeals (Case. No. 18-12488-P) Knight v. Sec’y, Fla. Dept. of Corrs., 958 F. 3d 1035 (11 2020) Affirmed May 1, 2020 ii