Inability to Appreciate the Criminality of Defendant's Conduct
In Nelson v. State, 850 So. 2d 514, 531 (Fla. 2003) the court upheld the trial court's ruling where the defendant removed the victim from her home after sexually assaulting her, drove to two separate orange groves before killing her, and lied to police about the crime.
The Court found that the defendant's "purposeful actions were indicative of someone who knew those acts were wrong and who could conform his conduct to the law if he so desired." Id.
Similarly, in Hoskins v. State, 965 So. 2d 1, 18 (Fla. 2007), the Court found that the trial court properly rejected the defendant's inability "to appreciate the criminality of his conduct" as mitigation where, after raping the victim, "Hoskins's purposeful actions in binding and gagging the victim before placing her in the trunk, driving to his parents' home six hours away, borrowing a shovel, driving to a remote area where he killed the victim, and then telling his brother he hit a possum when blood was noticed dripping from the rear wheel well were indicative of someone who knows his conduct is wrong."