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Florida Supreme Court – Criminal Headnotes – April 20, 2017

CLYDE EDWARD JOHNSON V. STATE OF FLORIDA – MILLER/GRAHAM RESENTENCING

A juvenile non-homicide offender is entitled to a sentence that provides a “meaningful opportunity for early release” based on demonstrated maturity and rehabilitation during his natural lifetime, and “gain time” does not meet this requirement.

ELIJAH BROOKINS V. STATE OF FLORIDA – IMPEACHMENT WITH COLLATERAL CRIMES EVIDENCE – COMMENT ON DEFENDANT’S SILENCE – HURST RELIEF

State may use evidence of collateral crime to impeach defendant’s inaccurate testimony on direct examination to material facts. State may use defendant’s voluntary pre-arrest statements to impeach trial testimony without violating Fifth Amendment right to silence. A less than unanimous jury recommendation of the death sentence pre-Hurst is not harmless beyond a reasonable doubt.

JUAN DAVID RODRIGUEZ V. STATE OF FLORIDA – SUFFICIENCY OF HUFF HEARING – HURST RELIEF

The trial court adequately considered evidence of all three prongs of the defendant’s intellectual disability — IQ, adaptive functioning deficits, and age of onset –, as required by the 2014 Supreme Court decision in Hall v. Florida, 134 S.Ct. 1986. Hurst v. Florida, 136 S. Ct. 616 (2016) does not apply retroactively to a case that was already final on direct appeal before the decision in Ring v. Arizona, 536 U.S. 584 (2002).