JAMES A. MORGAN, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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James A. Morgan, a 16-year-old convicted of first-degree murder and sentenced to death, appealed on the basis that the bifurcated trial procedure used at his trial violated due process by creating an irrebuttable presumption of intent. The Florida Supreme Court agreed and vacated his conviction and death sentence for a new trial.
The bifurcated insanity procedure violates due process by creating an irrebuttable presumption of intent, relieving the state of its burden to prove each element of the crime beyond a reasonable doubt. The defendant's failure to object at trial does not preclude appellate review because the law must be applied as it exists at the time of appeal. Therefore, the conviction and sentence are vacated and a new trial is granted.
[1] A bifurcated trial procedure that precludes evidence of insanity during the guilt phase denies a defendant due process of law by creating an irrebuttable presumption of i…
[2] A statute declared unconstitutional after a defendant's trial but before the appeal's resolution applies to cases pending on appeal.
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Join FLexlaw to unlock all legal intelligence“The basis of an insanity defense is that a person is unable to form the requisite intent. Since intent is an element of most crimes, lack of intent precludes criminal responsibility. Under the bifurcated system established by our Legislature, no evidence of insanity is admissible during that phase of the trial in which guilt or innocence is determined. Sanity is, in effect, presumed, giving rise to an irrebuttable presumption of the existence of the requisite intent. Thus, the State is relieved of its burden of proving each element of the offense beyond a reasonable doubt because the defendant is precluded from offering evidence to negate the presumption of intent.”
Establishes why the bifurcated procedure violates due process by creating an irrebuttable presumption of intent and relieving the state of its burden of proof.
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Join FLexlaw to unlock all legal intelligenceJames A. Morgan, age 16, was convicted of first-degree murder and sentenced to death. He pleaded not guilty and not guilty by reason of insanity. His …
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PER CURIAM.
The appellant, James A. Morgan, age sixteen, was convicted of first-degree murder. The trial judge imposed the death sentence in accordance with the jury’s advisory sentence recommendation. We have jurisdiction. Art. V, § 3(b)(1), Fla.Const. The appellant pleaded not guilty and not guilty by reason of insanity. He was convicted and sentenced under a bifurcated trial procedure adopted by the 1977 legislature and prescribed in section 918.017(1), Florida Statutes (1977). One phase of the procedure determined appellant’s guilt and the second determined that appellant was sane at the time of the offense. Subsequent to trial and while this matter was pending on appeal, we declared section 918.-017(l)’s bifurcated trial procedure unconstitutional because it denied a defendant his right of due process of law. State ex rel. Boyd v. Green, 355 So. 2d 789 (Fla.1978). In so holding, we stated:
The basis of an insanity defense is that a person is unable to form the requisite intent. Since intent is an element of most crimes, lack of intent precludes criminal responsibility. Under the bifurcated system established by our Legislature, no evidence of insanity is admissible during that phase of the trial in which guilt or innocence is determined. Sanity is, in effect, presumed, giving rise to' an irrebuttable presumption of the existence of the requisite intent. Thus, the State is relieved of its burden of proving each element of the offense beyond a reasonable doubt because the defendant is precluded from offering evidence to negate the presumption of intent.
Id. at 792-93. We concluded that because this bifurcated proceeding raised an irre-buttable presumption of intent, it was contrary to due process.
The state contends that appellant’s failure to object to the validity of the bifurcated insanity procedure at trial prevents him from asserting that issue before this Court. We reject this contention and find that, under the circumstances of this case, our decision must be determined by the law as it exists at the time of this appeal. Wheeler v. State, 344 So. 2d 244 (Fla.1977); cf. Florida E. Coast Ry. v. Rouse, 194 So. 2d 260 (Fla.1967). Consequently, our holding in State ex rel. Boyd that section 918.017(1) was unconstitutional as violative of due process must be applied to this case which was pending on appeal at the time of our State ex rel. Boyd decision. We also conclude that this bifurcated insanity procedure’s due process violation as established in State ex rel. Boyd concerns the element of intent to commit a crime and, therefore, adversely affects the truth-finding function. Given the circumstances of this cause, prejudice is apparent and fairness dictates that the defendant be afforded a new trial.
With this holding, it is unnecessary that we address appellant’s other issues. We do, however, direct the trial court’s attention to our recent decision in Lane v. State, 388 So. 2d 1022 (Fla.1980), concerning competency to stand trial.
Accordingly, we vacate both the judgment and sentence and remand for a new trial subject to the trial court’s finding appellant competent to stand trial.
It is so ordered.
SUNDBERG, C. J„ and ADKINS, BOYD, OVERTON, ENGLAND, ALDERMAN and McDONALD, JJ., concur.
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State v. Lavazzoli, 434 So. 2d 321 (Fla. 1983)…y dependent on the express language of former article I, section 12, Dodd is no longer controlling precedent. We have consistently held that our decisions must be determined by the law as it exists at the time of an appeal. See e.g. Morgan v. State, 392 So. 2d 1315 (Fla.1981); Wheeler v. State, 344 So. 2d 244 (Fla.1977). The application of this rule in criminal cases is [*325] obviously subject to the constitutional prohibition against ex post facto laws. Application of this new amendment would not amount to a…
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State v. Carlton Rolle, 560 So. 2d 1154 (Fla. 1990)…viction “except upon proof beyond a reasonable doubt of every fact necessary to constitute the crime with which he is charged.” In re Winship, 397 U.S. 358, 364, 90 S.Ct. 1068, 1072, 25 L.Ed.2d 368 (1970) (emphasis supplied). Accord Morgan v. State, 392 So. 2d 1315, 1316 (Fla.1981); State ex rel. Boyd v. Green, 355 So. 2d 789, 794 (Fla.1978); State v. Kohler, 232 So. 2d 166, 168 (Fla.1970); Cordell v. State, 157 Fla. 295, 296, 25 So. 2d 885, 886 (1946). To satisfy its burden of proof, the state must produce ev…
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Brennan v. State, 754 So. 2d 1 (Fla. 1999)…and two retrials, Morgan's death penalty was ultimately reduced to life imprisonment. See Morgan v. State, 639 So. 2d 6, 9 (Fla.1994); Morgan v. State, 537 So. 2d 973, 974 (Fla.1989); Morgan v. State, 453 So. 2d 394, 395 (Fla.1984); Morgan v. State, 392 So. 2d 1315, 1316 n. 1 (Fla.1981). . Only four members of the nine-person United States Supreme Court agreed with all parts of Justice Scalia’s five-part opinion in See Stanford v. Kentucky, 492 U.S. 361, 109 S.Ct. 2969, 106 L.Ed.2d 306 (1989); thus, the opini…
Previewing 3 of 8 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Fla. E. Coast Ry. Co. v. Rouse, 194 So. 2d 260 (Fla. 1966)
- Hayward Lane v. State, 388 So. 2d 1022 (Fla. 1980)
- Wheeler v. State, 344 So. 2d 244 (Fla. 1977)
- State of Fla. ex rel. Jeffrey Michael Boyd v. Green, 355 So. 2d 789 (Fla. 1978)