Heilman v. State, 135 So. 3d 513

Heilman, a Florida Department of Corrections officer, was at Lake Correctional Institution when he and an inmate fought, injuring the inmate.
Heilman was charged with aggravated battery and moved under section 776.032 to dismiss and requested a hearing.
The trial court denied the motion, relying on State v. Caamano (Fla. 2d DCA 2012) to hold 944.35(l)(a) governs use of force by correctional officers.
The Caamano rationale treated a more specific statute as precluding the stand-your-ground defense, implying 776.032 did not apply.
The Florida Supreme Court granted Heilman’s petition for a writ of prohibition to determine whether 944.35(l)(a) preempts 776.032 for correctional officers.
The court ultimately held that 944.35(1) does not preempt 776.032, and 776.032 applies to correctional officers with the exception in 776.07(2).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether 944.35(l)(a) preempts 776.032 for correctional officers	Heilman: 944.35(l)(a) precludes 776.032 defense	State: 944.35(l)(a) governs force criteria, not stand-your-ground	No preemption; 776.032 applies (with 776.07(2) exception)
Whether Caamano governs the applicability of 776.032 to correctional officers	Caamano indistinguishably suggested preemption	Caamano distinguishes police context, not correctional officers	Caamano distinguishable; not controlling here

State v. Caamano, 105 So.3d 18 (Fla. 2d DCA 2012) (distinguishes officer-specific statutes; not controlling for corrections officers here)
Macchione v. State, 123 So.3d 114 (Fla. 5th DCA 2013) (illustrates rule against meaningless provisions; avoid useless readings)
Bautista v. State, 863 So.2d 1180 (Fla.2003) (statutory construction guiding intent; polestar principle)
State v. Wonder, 128 So.3d 867 (Fla. 4th DCA 2013) (de novo standard of review for statutory interpretation)
State v. Goode, 830 So.2d 817 (Fla.2002) (statutory interpretation guidance)