 In 1984, the Florida Supreme Court held that Zeigler had procedurally defaulted this claim because he could have raised it by the close of the trial but did not.Other arguments include that the murder investigation was complicated and the trial rushed and complicated, that the verdict was returned only after Judge Paul, without the defense team's knowledge, arranged for the hold-out juror's doctor to prescribe her Valium, and that a statement by Judge Paul during a conversation between the government and Judge Paul revealed bias on the part of Judge Paul.In 1984, the Florida Supreme Court held that all but two of these arguments—one involving an allegation of ineffective assistance of counsel and the other involving the allegation of judicial bias based on Judge Paul's conversation with the government—were procedurally defaulted because they were presented and rejected on direct appeal, or could have been presented, at trial or on direct appeal, but were not.