Haygood v. State
2011 Fla. App. LEXIS 1068
| Fla. Dist. Ct. App. | 2011Background
- Haygood was convicted of second-degree murder and sentenced to life in prison.
- He argued fundamental error occurred by giving the standard manslaughter by act instruction.
- Evidence showed Haygood head-butted, choked, and elbowed his girlfriend, causing fatal brain injury.
- In post-Miranda interviews, Haygood admitted actions but claimed the death was accidental.
- The trial courts instructed on second-degree murder and both manslaughter by culpable negligence and manslaughter by act; the act instruction was flawed
- The district affirmed the conviction but certified a question of great public importance for Supreme Court review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is giving the flawed manslaughter by act instruction fundamental error when second-degree murder is charged? | Haygood argues Montgomery mandating fundamental error. | State contends Nieves/Barros-Dias align with no fundamental error if lesser offenses are also charged. | Yes; but court affirms conviction due to district precedent, and certifies the question. |
| Does instruction on manslaughter by culpable negligence cure the error from manslaughter by act? | Haygood would be harmed by improper instruction; negligence manslaughter incomplete remedy. | Culpable negligence instruction mitigates risk, not converting to fundamental error. | Court holds that the negligence instruction does not cure the error for Montgomery-based fundamental error analysis. |
| Should the Supreme Court be asked to resolve the proper rule for this scenario? | Issue is of great public importance and requires Supreme Court guidance. | Existing district precedents are adequate for disposition and review. | Certified question presented to Florida Supreme Court as one of great public importance. |
Key Cases Cited
- Montgomery v. State, 39 So. 3d 252 (Fla. 2010) (manslaughter by act does not require intent to kill; error when applied to second-degree murder conviction)
- Nieves v. State, 22 So. 3d 691 (Fla. 2d DCA 2009) (juries may be instructed on lesser offenses; district precedent follows Nieves)
- Barros-Dias v. State, 41 So. 3d 370 (Fla. 2d DCA 2010) (acknowledges Nieves approach to manslaughter instructions and non-fundamental error when lesser offenses are charged)
- Singh v. State, 36 So. 3d 848 (Fla. 4th DCA 2010) (reiterates Nieves approach to manslaughter instruction)
- Salonko v. State, 42 So. 3d 801 (Fla. 1st DCA 2010) (further supports non-fundamental error where culpable negligence manslaughter is also instructed)
- Pena v. State, 901 So. 2d 781 (Fla. 2005) (pardon power requires proper instruction on next lower offense)
- Reed v. State, 837 So. 2d 366 (Fla. 2002) (fundamental error Harm requirement; inherent fairness principle)
- Sanders v. State, 946 So. 2d 953 (Fla. 2006) (explains jury’s pardon power and ability to convict of lesser offense)