Haygood v. State
109 So. 3d 735
| Fla. | 2013Background
- Haygood was tried for second-degree murder in Pinellas County based on a November 2008 beating of his girlfriend, which left her in a coma and later caused death.
- Prosecution evidence showed repeated head-butting, kicks, choking, and chest impacts; Haygood admitted to intended striking but claimed death was not intended.
- The jury was instructed on second-degree murder and on the lesser offense of manslaughter, with the manslaughter instruction including both act and culpable negligence theories.
- The jury found Haygood guilty of second-degree murder; on appeal, Haygood argued the manslaughter by act instruction was fundamental error per Montgomery and that it tainted the verdict.
- The Second District affirmed, citing Nieves to distinguish cases where culpable negligence was instructed; it certified the question of whether erroneous act-based manslaughter instruction constitutes fundamental error when evidence supports only act-based manslaughter.
- This Court held that the erroneous manslaughter by act instruction is fundamental error even if culpable negligence instructions are also given, when the evidence supports only manslaughter by act and not culpable negligence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is the manslaughter by act instruction fundamental error | Haygood | State | Yes; fundamental error. |
| Does culpable negligence instruction cure the error | Haygood | State | No; culpable negligence instruction does not cure the error. |
| Does Florida's jury pardon doctrine underlie the decision | Haygood | State | No; the decision rests on accurate instruction and fundamental error analysis, not on jury pardon doctrine. |
Key Cases Cited
- Montgomery v. State, 39 So.3d 252 (Fla. 2010) (erred manslaughter by act instruction fundamental error when second-degree murder conviction)
- Pena v. State, 901 So.2d 781 (Fla. 2005) (harmless error analysis when instruction not proper but not tantamount to per se reversible error)
- Reed v. State, 837 So.2d 366 (Fla. 2002) (fundamental error when erroneous instruction related to a disputed element)
- Delva v. State, 575 So.2d 643 (Fla. 1991) (principles regarding materiality of disputed elements for conviction)
- Wimberly v. State, 498 So.2d 929 (Fla. 1986) (jury pardon concept tied to lesser included offenses)
- Lucas v. State, 645 So.2d 425 (Fla. 1994) (per se reversible error for failure to instruct on lesser included offenses when no evidence)
- Abreu v. State, 363 So.2d 1063 (Fla. 1978) (policy concept of jury pardon supporting requiring lesser included offense instruction)
- State v. Montgomery, 41 So.3d 370 (Fla. 2d DCA 2010) (intermediate appellate decision applying Montgomery principles)
- Nieves v. State, 22 So.3d 691 (Fla. 2d DCA 2009) (jury instruction on lesser included offenses considered with lack of evidence)