Matarranz v. State
133 So. 3d 473
| Fla. | 2013Background
- Defendant Rafael Matarranz was convicted of first-degree murder and burglary; he appealed claiming a juror (the Juror) should have been excused for cause because of bias arising from prior burglary victimization.
- During voir dire the Juror said she held a "grudge" from childhood burglaries and initially indicated she would "lean" toward the State, though later after questioning she said she could keep an open mind.
- The trial court denied defense counsel’s challenge for cause; defense used a peremptory strike on the Juror but exhausted all peremptories and was denied an extra challenge.
- The Third District Court of Appeal affirmed, finding the Juror competent because she acknowledged the State’s burden and said she could be fair.
- The Florida Supreme Court granted review (conflict with Huber) and held the Juror should have been excused for cause, quashed the Third District, and remanded for a new trial.
Issues
| Issue | Plaintiff's Argument (Matarranz) | Defendant's Argument (State / Trial Court) | Held |
|---|---|---|---|
| Whether the Juror should have been excused for cause due to bias from prior victimization | Juror’s statements that she "held a grudge," would "lean" to the State, and initial equivocation showed reasonable doubt about impartiality | Juror later affirmed she could follow law, accept presumption of innocence, and hold State to burden; trial court credited her recantation | Court held Juror demonstrated inability to be impartial and should have been excused for cause; conviction vacated and new trial ordered |
| Whether defendant preserved the challenge for appellate review | Counsel moved to strike for cause, used a peremptory to remove the Juror, exhausted peremptories, then identified jurors he would have excused if given more; preservation satisfied | State argued defendant failed to renew identification of the specific juror prior to swearing | Held preserved: exhaustion of peremptories plus naming jurors for additional strike met preservation requirements |
| Standard for reviewing trial court denial of challenge for cause | N/A (appellate review asks whether juror bias created reasonable doubt of impartiality) | Trial court’s demeanor-based credibility finding entitled to deference; manifest error standard | Court reiterates manifest-error/mixed fact-law review but found record did not support trial court’s competency finding; vacated under that standard |
| Proper scope of juror "rehabilitation" during voir dire | Jurors whose bias stems from immutable personal experiences cannot reliably be rehabilitated by questioning; recantation caused by embarrassment is suspect | Rehabilitation/statutory framework permits the court to credit a juror’s recantation and determine state of mind; human beings can change | Court clarifies distinction: rehabilitable misunderstandings of law vs. non-rehabilitable fixed biases from personal experience; here bias was non-rehabilitable |
Key Cases Cited
- Singer v. State, 109 So.2d 7 (Fla. 1959) (if any reasonable doubt exists about a juror’s impartiality, juror should be excused)
- Hill v. State, 477 So.2d 553 (Fla. 1985) (reversible error to force party to use peremptories on jurors who should be excused for cause)
- Kearse v. State, 770 So.2d 1119 (Fla. 2000) (preservation requirements for challenges for cause: object, exhaust peremptories, identify a juror who would have been excused)
- Overton v. State, 801 So.2d 877 (Fla. 2001) (distinguishing jurors with fixed beliefs from those susceptible to rehabilitation)
- Hamilton v. State, 547 So.2d 630 (Fla. 1989) (equivocal assurances of impartiality insufficient where other responses raise doubt)
- Huber v. State, 669 So.2d 1079 (Fla. 4th DCA 1996) (conflicting district decision about excusing a juror who doubted presumption of innocence)
- Wainwright v. Witt, 469 U.S. 412 (U.S. 1985) (trial judge’s demeanor and credibility determinations in voir dire are accorded deference)