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Keywords

defendantstatutetrialmotionhabeas corpusjury trial
statuteprecedenthabeas corpus

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Bottoson v. Moore, 833 So.2d 693, 27 Fla. L. Weekly S891

Facts

Linroy Bottoson was convicted of first-degree murder and sentenced to death. After his conviction was affirmed and his postconviction motion was denied, he sought relief through a petition for writ of habeas corpus, arguing that the U.S. Supreme Court's decision in Ring v. Arizona rendered Florida's capital sentencing statute unconstitutional. The Florida Supreme Court had previously upheld Florida's capital sentencing statute in numerous cases, and Bottoson's execution had been stayed while the U.S. Supreme Court considered Ring.

Linroy Bottoson, a prisoner under sentence of death and an active death warrant, petitions this Court for a writ of habeas corpus. He seeks relief pursuant to Ring v. Arizona, wherein the United States Supreme Court held unconstitutional the Arizona capital sentencing statute 'to the extent that it allows a sentencing judge, sitting without a jury, to find an aggravating circumstance necessary for imposition of the death penalty.'

Issue

Whether the U.S. Supreme Court's decision in Ring v. Arizona rendered Florida's capital sentencing statute unconstitutional as applied to Bottoson.

Whether the United States Supreme Court's decision in Ring v. Arizona rendered Florida's capital sentencing statute unconstitutional as applied to Bottoson.

Rule

The U.S. Supreme Court in Ring v. Arizona held that a sentencing judge, sitting without a jury, cannot find an aggravating circumstance necessary for the imposition of the death penalty, as this violates the defendant's Sixth Amendment right to a jury trial.

The United States Supreme Court in Ring v. Arizona held unconstitutional the Arizona capital sentencing statute 'to the extent that it allows a sentencing judge, sitting without a jury, to find an aggravating circumstance necessary for imposition of the death penalty.'

Analysis

The Florida Supreme Court analyzed the implications of the Ring decision and concluded that it did not affect Florida's capital sentencing scheme. The court noted that in Florida, the jury is involved in the sentencing process and makes recommendations based on the evidence presented, which distinguishes it from the Arizona scheme criticized in Ring. The court emphasized that Florida's statute has been upheld by the U.S. Supreme Court in previous cases.

Significantly, the United States Supreme Court repeatedly has reviewed and upheld Florida's capital sentencing statute over the past quarter of a century, and although Bottoson contends that there now are areas of 'irreconcilable conflict' in that precedent, the Court in Ring did not address this issue.

Conclusion

The Florida Supreme Court denied Bottoson's petition for habeas relief, allowing the execution to proceed as scheduled.

Accordingly, we deny Bottoson's petition for habeas relief.

Who won?

The State of Florida prevailed in the case, as the court upheld the constitutionality of Florida's capital sentencing statute and denied Bottoson's petition for relief.

The State has sentenced individuals to death, confined individuals in a severe and special state of confinement with limited privileges, and executed fifty-three individuals in reliance on the constitutionality of Florida's capital sentencing statute as determined by the decisions of the United States Supreme Court.

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