STATE OF FLORIDA v. JOHN CHAPMAN
227 So. 3d 626
| Fla. Dist. Ct. App. | 2017Background
- State filed petition for writ of prohibition challenging a trial court order that precluded the death penalty and death-qualifying the jury in John Chapman’s pending prosecution.
- Trial court had ruled the State could not pursue death because no constitutional penalty-phase procedure (as then interpreted) existed for pending cases.
- The Fourth District considered recent Florida Supreme Court and legislative developments addressing the death penalty statute and unanimity requirements for jury recommendations.
- The court found controlling precedent holds that aggravating factors need not be alleged in the indictment and that trial courts may not bar the State from seeking death on that basis.
- While the petition was pending, the Florida Supreme Court denied related writ petitions on the merits, signaling it would not recede from its precedent.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial court may preclude death as a possible punishment and bar death-qualifying the jury because of alleged procedural defects in the death penalty statute | State: Trial court erred; prosecutorial discretion and statute permit death seeking and death-qualification | Chapman: No constitutional penalty-phase procedure in place for pending prosecutions, so death cannot be sought | Granted the State’s petition; quashed trial court order and allowed death as a possible punishment and jury death-qualification |
| Whether aggravating factors must be alleged in the indictment for the State to seek death | State: Precedent allows aggravating factors to be proven at trial without indictment allegations | Chapman: Failure to allege aggravators in indictment precludes seeking death | Court reaffirmed precedent that aggravating factors need not be alleged in the indictment |
| Whether recent Florida Supreme Court decisions or legislative amendments change binding precedent on death-penalty procedure | State: Supreme Court decisions and Legislature preserved or remedied statute; precedent remains controlling | Chapman: Recent developments negate the State’s ability to seek death in pending cases | Court held Supreme Court and legislative actions support applying the death penalty statute and did not signal overruling of controlling precedent |
| Appropriate remedy for a trial court interfering with prosecutorial discretion | State: Writ of prohibition is proper remedy | Chapman: Implicitly opposed | Writ of prohibition granted; trial court order quashed |
Key Cases Cited
- Jones v. State, 209 So. 3d 6 (Fla. 2d DCA 2016) (recognized prohibition relief and quash of pretrial order barring death penalty)
- Bloom v. State, 497 So. 2d 2 (Fla. 1986) (writ of prohibition appropriate when trial court interferes with state attorney’s prosecutorial discretion)
- Evans v. State, 213 So. 3d 856 (Fla. 2017) (death penalty statute can be constitutionally applied in pending prosecutions where jury unanimity is met)
- Puryear v. State, 810 So. 2d 901 (Fla. 2002) (Florida Supreme Court precedent binding and does not silently overrule itself)
- Perry v. State, 210 So. 3d 630 (Fla. 2016) (identified problematic statutory language later addressed by the Legislature)
- Topps v. State, 865 So. 2d 1253 (Fla. 2004) (denials on the merits can have preclusive effect regarding issues presented to the Supreme Court)