Beckman v. State
230 So. 3d 77
| Fla. Dist. Ct. App. | 2017Background
- On April 12, 2009, then-17-year-old Jason Beckman shot and killed his father with a two-barrel shotgun in the family bathroom; Beckman immediately called 911 and said he "accidentally shot" his father.
- Police found in Beckman’s backpack a handwritten "The List" ranking ten people (father marked V = deserved death); State presented witnesses who described how names were placed on the list and that Beckman had expressed hatred toward his father.
- While jailed, Beckman shared a cell with Michael Nistal, who told police Beckman said he kept another list in jail and expressed threats toward potential trial witnesses; Nistal testified at trial.
- Defense sought to present evidence that Beckman has Asperger’s syndrome; the trial court barred medical/expert testimony of Asperger’s, but allowed lay testimony that Beckman acted and spoke oddly.
- Trial court excluded the 911 recording as not an excited utterance (court found opportunity to fabricate based on prior statements Beckman made to a friend), admitted The List and Nistal’s testimony, convicted Beckman of first-degree premeditated murder, and after a Miller-compliant individualized hearing sentenced him to life with review after 25 years.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of "The List" and witness testimony about why names were placed on it | The List and surrounding witness testimony are inextricably intertwined and necessary to show context, motive, and intent | Testimony about unrelated incidents that put people on The List is collateral bad-act evidence and only shows propensity | Admitted: Court held testimony about entries and circumstances was inextricably intertwined under §90.402 and probative value outweighed prejudice; no abuse of discretion (Dorsett standard) |
| Admissibility of jailhouse list (Nistal testimony) | Relevant to show consciousness of guilt and threats to witnesses | Character/bad-acts evidence impermissible propensity proof | Admitted: Permissible as consciousness of guilt; trial court did not abuse discretion |
| Evidence Beckman has Asperger’s syndrome | Defense: medical evidence explains demeanor/mental state and could rebut premeditation theory | State: evidence would be admitted for diminished capacity (inadmissible); Chestnut prohibits non-insanity mental-condition evidence on mens rea | Excluded: Trial court properly limited to lay testimony about odd behavior; expert Asperger’s testimony inadmissible to negate premeditation under Chestnut; no abuse of discretion |
| Admissibility of 911 call as excited utterance | Call made ~1 minute after shooting, sounded hysterical, therefore admissible as excited utterance | Court and State: evidence Beckman previously planned/stated intent to stage shooting shows opportunity to fabricate; call not sufficiently spontaneous | Excluded: Court did not err—opportunity/likelihood to contrive made statement untrustworthy; exclusion reviewed for abuse of discretion and affirmed |
| Prosecutor closing argument (multiple comments) | Defense claims misleading comments, comments on silence, and denigration warrant mistrial | State: most comments were fair comment; only four were objected to; unobjected comments reviewed for fundamental error | Denied: For preserved objections, no abuse of discretion; unpreserved comments do not amount to fundamental error when considered cumulatively |
| Challenge under Apprendi to Florida’s Miller-based juvenile sentencing (§921.1401) | Beckman: individualized judicial sentencing hearing (judge, not jury, considering youth factors) violates Sixth Amendment/Apprendi because judge found facts affecting maximum penalty | State: Miller factors are mitigating/contextual sentencing considerations that do not increase statutory maximum; judge may consider them when imposing sentence within statutory range | Rejected: Court follows reasoning (e.g., People v. Hyatt)—Miller’s individualized sentencing does not raise Apprendi issue; judge’s findings are sentencing factors within statutory range, not elements requiring jury verdict |
Key Cases Cited
- Apprendi v. New Jersey, 530 U.S. 466 (U.S. 2000) (facts increasing penalty beyond statutory maximum must be submitted to a jury)
- Miller v. Alabama, 567 U.S. 460 (U.S. 2012) (mandatory life without parole for juveniles violates Eighth Amendment; individualized sentencing required)
- Williams v. State, 110 So. 2d 654 (Fla. 1959) (Williams rule on admission of uncharged crimes evidence)
- Chestnut v. State, 538 So. 2d 820 (Fla. 1989) (inadmissibility of non-insanity mental-condition evidence to negate mens rea/diminished capacity)
- Dorsett v. State, 944 So. 2d 1207 (Fla. 3d DCA 2006) (standard for inextricably intertwined evidence under §90.402)