BROWN
v.
STATE OF FLORIDA
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A conviction by a six-person jury does not violate the Sixth Amendment to the U.S. Constitution.
[1] A conviction by a six-person jury does not violate the Sixth Amendment to the United States Constitution.
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Join FLexlaw to unlock all legal intelligenceSteven Joseph Brown was found guilty by a jury as a principal to petit theft. He appealed his judgment and sentence, raising two issues regarding the …
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DISTRICT COURT OF APPEAL OF FLORIDA
SECOND DISTRICT
STEVEN JOSEPH BROWN, Appellant,
V.
STATE OF FLORIDA, Appellee.
No. 2D2025-1071
September 9, 2026
Appeal from the County Court for Pinellas County; Diane M. Croff, Judge.
Blair Allen, Public Defender, and Caroline Joan A. Picart, Assistant Public Defender, Bartow, for Appellant.
James Uthmeier, Attorney General, Tallahassee, and William A. Leto, Assistant Attorney General, Tampa, for Appellee.
PER CURIAM.
Steven Joseph Brown appeals his judgment and sentence after a jury found him guilty as a principal to petit theft. We have jurisdiction. See Fla. R. App. P. 9.030(b)(1)(A). He raises two issues.
Mr. Brown first argues that the trial court erred in denying his motion for judgment of acquittal. This claim lacks merit.
Next, he argues that his conviction by a six-person jury violates the Sixth Amendment to the U.S. Constitution. This claim, too, is meritless. See Williams v. Florida, 399 U.S. 78, 86 (1970); see also Serrano-Delgado v. State, 392 So. 3d 251, 253-54 (Fla. 2d DCA 2024). But see Kian v. Florida, 421 So. 3d 439 (Fla. 4th DCA 2025) (table decision); Pet. for Writ of Cert. at ii, Kian v. Florida, No. 25-6623 (U.S. Jan. 9, 2026) (presenting the Court with the question of whether petitioner "was derived [sic] of his right, under the Sixth and Fourteenth Amendments, to a trial by a 12- person jury when the defendant is charged with a serious felony"), cert. granted, No. 25-6623, 2026 WL 1718018 (U.S. June 15, 2026).
Affirmed.
SILBERMAN, LaROSE, and GUARD, JJ., Concur.
Opinion subject to revision prior to official publication.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Williams v. Florida, 399 U.S. 78 (U.S. 1970)
- Hamed Kian v. State, 421 So. 3d 439 (Fla. 4th DCA 2025)