Rodriguez v. State, 2D15-2961

Defendant Jose Albino Rodriguez was convicted of conspiracy to traffic in heroin and trafficking in heroin; he appealed to the Second District Court of Appeal.
During voir dire several prospective jurors (Jurors 8, 13, 16, and 20) indicated they might give greater credibility to law enforcement testimony.
The prosecutor requested a brief opportunity to rehabilitate those jurors; the trial court denied the request and refused further questioning.
Defense counsel moved to strike the listed jurors for cause and later objected after exhausting peremptory challenges; the court denied the cause challenges and refused an additional peremptory strike.
On appeal the court found reversible error in denying challenges for cause as to Jurors 13, 16, and 20 (who were not rehabilitated), reversed the convictions, and remanded for a new trial.

Issue	Plaintiff's Argument (Rodriguez)	Defendant's Argument (State)	Held
Whether jurors who say they give extra credibility to law enforcement must be excused for cause	Jurors 13, 16, and 20 explicitly said yes and were not rehabilitated; their presence created reasonable doubt as to impartiality	The jurors never said they could not be fair or follow the court's instructions; absence of express inability to follow law meant no cause for removal	Reversed: Jurors 13, 16, and 20 should have been excused for cause because their unrehabilitated answers raised reasonable doubt about impartiality
Whether trial court abused discretion by denying request to rehabilitate jurors	Defense implies denying rehabilitation left only biased answers on the record	State argued jurors' answers didn't show inability to be impartial without asking about following instructions	Court noted trial court's denial of rehabilitation prevented clarification; this supported reversal for unrehabilitated jurors
Whether error was harmless	Rodriguez argued error undermined verdict and required reversal	State asserted harmless error without citation	Court held harmless-error rule did not apply; per se reversal required for jury-selection error in these circumstances
Whether English transcripts of Spanish calls can be used on remand	Not raised as a central error; court provided guidance	N/A	Court instructed that if transcript accuracy is disputed, jury instruction (Fla. Std. Jury Instr. (Crim.) 2.11) should be read on remand

Matarranz v. State, 133 So. 3d 473 (court must ensure jury members are fair and impartial)
Carratelli v. State, 961 So. 2d 312 (manifest error when record shows reasonable doubt about juror impartiality)
Freeman v. State, 50 So. 3d 1163 (equivocal or conditional juror answers raising reasonable doubt require excusal)
Thomas v. State, 958 So. 2d 1047 (in close cases, doubts about juror competency resolved in favor of excusal)
Salgado v. State, 829 So. 2d 342 (equivocal juror answers create reasonable doubt as to impartiality)
Vega v. State, 182 So. 3d 848 (juror bias in favor of law enforcement requires excusal)
Rimes v. State, 993 So. 2d 1132 (permitting rehabilitation of concerned jurors is allowed)
Garcia v. State, 805 So. 2d 827 (bias toward law enforcement testimony warrants cause challenge)