Gonzalez v. State
50 So. 3d 633
| Fla. Dist. Ct. App. | 2010Background
- Gonzalez, at 16, was convicted of first-degree premeditated murder and sentenced to life in prison.
- The murder involved stabbing the 49-year-old, in poor health, who weighed 108 pounds, 12 times.
- Gonzalez stated in a post-Miranda interview that he acted for revenge over a racist remark.
- The defense suggested possible mental disorder, which testing would probably reveal, but no evidence was presented in the record.
- The State argued the death penalty was not applicable and emphasized the gravity of the offense and the age of the offender.
- The Florida appellate court affirmed the sentence, rejecting the gross disproportionality claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a life sentence for juvenile first-degree murder is grossly disproportionate | Gonzalez argues disproportionate given youth and circumstances | State contends proportionality evidence supports life sentence | Not grossly disproportionate; affirmed |
Key Cases Cited
- Graham v. Florida, 130 S. Ct. 2011 (2010) (categorical rules on juvenile life sentences; life without parole for nonhomicide prohibited)
- Roper v. Simmons, 543 U.S. 551 (2005) (death penalty unconstitutional for under 18; life sentence permissible)
- Solem v. Helm, 463 U.S. 277 (1983) (guides gross disproportionality analysis with objective factors)
- Adaway v. State, 902 So.2d 746 (Fla.2005) (life sentence not grossly disproportionate in some egregious offenses; age weighed against crime)
- Phillips v. State, 807 So.2d 713 (Fla.2002) (life for first-degree murder not disproportionate for a juvenile)
- Tate v. State, 864 So.2d 44 (Fla.2003) (life sentence for a juvenile murder not grossly disproportionate)
- Montana v. Egelhoff, 518 U.S. 37 (1996) (voluntary intoxication not a defense; deterrent rationale upheld)