THE STATE OF FLORIDA, APPELLANT,
v.
JOHNNY WILLIAMS, APPELLEE
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Florida's appellate court reversed the trial court's dismissal of robbery and burglary charges after a jury deadlocked, holding that a guilty verdict on a lesser-included offense does not establish that the State failed to prove an essential element of the greater offense.
A jury's deadlock on robbery and burglary charges does not warrant dismissal merely because the jury convicted on a lesser-included offense, as each count is independent and verdicts need not be logically consistent absent a narrow exception.
[1] Verdicts on separate counts in an information are independent and need not be logically consistent absent a narrow exception where verdicts are legally inconsistent.
Previewing 1 of 1 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“absent a narrow exception where the verdicts are legally inconsistent, verdicts which are inconsistent are not flawed, as each count in an information is considered separate and independent”
The court explained the proper standard for evaluating consistency among verdicts on multiple counts.
The defendant was charged with robbery, carjacking, and burglary of a conveyance with assault. The jury convicted on petit theft as a lesser-included …
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PER CURIAM.
Pursuant to rule 9.140(c)(1)(A) of the Florida Rules of Appellate Procedure, the State appeals an order of the trial court which dismissed two counts of an information. The defendant was charged with robbery, carjacking, and burglary of a conveyance with assault.
The jury found the defendant guilty of petit theft as a lesser-included offense of the robbery charge, but deadlocked as to the two remaining counts.
The trial court granted the defendant’s motion to dismiss these two counts, finding that the verdict indicated the State failed to prove the element of violence; the State appealed.
We reverse the order of the trial court. See Streeter v. State, 416 So. 2d 1203, 1206 (Fla. 3d DCA 1982) (noting that, absent a narrow exception where the verdicts are legally inconsistent, verdicts which are inconsistent are not flawed, as each count in an information is considered separate and independent); State v. Bryant, 373 So. 2d 708, 709 (Fla. 3d DCA 1979) (“[T]he trial court erred by granting the motion to dismiss because there were justiciable issues of fact which, if construed most favorably to appellant, raised a prima facie case of guilt.”).
Reversed and remanded for further proceedings consistent with this opinion.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Murrell Streeter v. State, 416 So. 2d 1203 (Fla. 3d DCA 1982)
- State v. Bryant, 373 So. 2d 708 (Fla. 3d DCA 1979)