Torrence Lawton v. State of Florida
181 So. 3d 452
| Fla. | 2015Background
- Torrence Lawton, a juvenile at the time, received life-without-parole (LWOP) sentences for nonhomicide offenses (attempted first-degree murder with a firearm; armed robbery with a firearm) committed in the same criminal episode as a homicide.
- The Third District Court of Appeal upheld those LWOP sentences, adopting a "homicide-case exception" to Graham v. Florida allowing LWOP for nonhomicide offenses when a homicide occurred in the same episode.
- Lawton sought review in the Florida Supreme Court, arguing the Third District’s approach conflicted with other district courts that declined to recognize a homicide-case exception.
- Multiple Florida district courts were split: some recognized a homicide-case exception (Second, Third, Fourth), while others (First, Fifth) rejected it.
- The Florida Supreme Court limited review to Lawton’s nonhomicide LWOP sentences and did not address his homicide sentence.
- The Court concluded Graham established a categorical, unqualified ban on LWOP for juvenile nonhomicide offenders and ordered resentencing under Florida’s post-2014 juvenile sentencing scheme.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Graham allows a "homicide-case exception" permitting LWOP for juvenile nonhomicide offenses committed in the same episode as a homicide | Lawton: Graham prohibits LWOP for juvenile nonhomicide offenses categorically; no exception for co-occurring homicide | State/Third DCA: Graham allows an exception when the juvenile also committed a homicide in the same criminal episode | The Court held Graham’s categorical ban on LWOP for juvenile nonhomicide offenses is unqualified; no homicide-case exception allowed |
| Whether the Third District’s decision conflicts with other district courts | Lawton: Third District conflicts with First and Fifth DCA decisions that declined the exception | State: Third DCA followed precedent recognizing the exception (Second, Fourth DCAs) | The Court found the Third District’s rule incompatible with Graham and quashed the Third District decision |
| Remedy for a sentence that violates Graham where juvenile received LWOP for nonhomicide offenses | Lawton: Sentences must be vacated and juvenile resentenced consistent with Graham and state law | State: (implicit) uphold sentence under Third DCA approach | Court ordered resentencing under chapter 2014-220, Laws of Florida (Florida’s juvenile sentencing statute) |
| Whether to approve district decisions recognizing the homicide-case exception | Lawton: Those decisions are incorrect and should be disapproved | State/Other DCAs: Those decisions are valid interpretations of Graham | The Court disapproved the Second and Fourth District decisions to the extent they recognize such an exception |
Key Cases Cited
- Graham v. Florida, 560 U.S. 48 (2010) (categorical Eighth Amendment bar on LWOP for juveniles convicted of nonhomicide offenses)
- Miller v. Alabama, 132 S. Ct. 2455 (2012) (distinguishing Graham’s flat ban for nonhomicide offenses from individualized sentencing required in juvenile homicide cases)
- Lawton v. State, 109 So. 3d 825 (Fla. 3d DCA 2013) (Third DCA opinion recognizing a homicide-case exception; quashed)
- Akins v. State, 104 So. 3d 1173 (Fla. 1st DCA 2012) (refusing to recognize a homicide-case exception to Graham)
- Washington v. State, 110 So. 3d 1 (Fla. 2d DCA 2012) (recognizing homicide-case exception; disapproved to the extent it so holds)
- Starks v. State, 128 So. 3d 91 (Fla. 2d DCA 2013) (recognizing homicide-case exception; disapproved to the extent it so holds)
- Orange v. State, 149 So. 3d 74 (Fla. 4th DCA 2014) (recognizing homicide-case exception; disapproved to the extent it so holds)
- Weiand v. State, 129 So. 3d 434 (Fla. 5th DCA 2013) (declining to recognize homicide-case exception)
- Lane v. State, 151 So. 3d 20 (Fla. 1st DCA 2014) (declining to recognize homicide-case exception)