Ranglin v. State
55 So. 3d 744
| Fla. Dist. Ct. App. | 2011Background
- Ranglin was charged with aggravated battery of his former girlfriend Potts and was convicted of the lesser included offense of battery after a jury trial.
- Ranglin asserted self-defense; Potts testified Ranglin assaulted her during Potts's birthday visit to Ranglin's home.
- During voir dire, Juror Kenneally stated there were no circumstances under which it is appropriate for a man to strike a woman.
- Ranglin moved to strike Kenneally for cause; the trial court denied the motion, and Ranglin used a peremptory challenge to excuse Kenneally.
- Ranglin had exhausted his peremptory challenges and sought additional peremptories, which the trial court denied; he preserved the issue by not accepting the jury as sworn.
- The appellate court held that denial of the for-cause challenge required reversal and remand for a new trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court erred in denying the cause strike for Kenneally | Kenneally could not be impartial against self-defense | Judge properly denied cause strike; juror could be neutral | Abuse of discretion; error in denial |
| Whether the for-cause error requires a new trial given exhausted peremptories | Exhaustion of peremptories due to improper denial mandates new trial | Peremptory exhaustion may not always require remand | Remand for a new trial |
Key Cases Cited
- Singleton v. State, 783 So.2d 970 (Fla.2001) (abuse of discretion standard for cause challenges)
- Singer v. State, 109 So.2d 7 (Fla.1959) (limits of trial court's discretion on juror qualifications)
- Montozzi v. State, 633 So.2d 563 (Fla.4th DCA 1994) (abuse of discretion when impartiality is in doubt)
- Bryant v. State, 765 So.2d 68 (Fla.4th DCA 2000) (close cases favor excusing jurors to preserve impartiality)
- Busby v. State, 894 So.2d 88 (Fla.2004) (peremptory challenges and cause challenges interplay)
- Trotter v. State, 576 So.2d 691 (Fla.1991) (reversible error when improper denial affects jury)
- Carratelli v. State, 961 So.2d 312 (Fla.2007) (juror need not be legally objectionable; harm from improper denial)
- Bell v. Greissman, 902 So.2d 846 (Fla.4th DCA 2005) (peremptory challenges and cure for cause error)