Bell — affirmed the conviction over a jury-size challenge

Case
Demetrius Tyrone Bell v. State of Florida
Court
Florida Second District Court of Appeal
Judge
LaRose; Khouzam; Black
Date Decided
October 30, 2026
Docket No.
2D2025-1110
Topics
Criminal Appeals, Jury Size, Sixth Amendment
Source
Read the full opinion

Background

Demetrius Tyrone Bell appealed a judgment entered by the Circuit Court for Manatee County. The Second District’s short per curiam opinion does not identify Bell’s offense, sentence, or the detailed procedural history.

The authorities cited by the court indicate that the appeal concerned the constitutional right to a twelve-person jury. The court cited the U.S. Supreme Court’s decision in Williams v. Florida and its own decision in Serrano-Delgado v. State, while noting a contrary-position certiorari petition in Kian v. Florida that the Supreme Court had agreed to review.

The Court’s Holding

The Second District affirmed the circuit court’s judgment. Its citation to Williams and Serrano-Delgado reflects rejection of Bell’s jury-size challenge under the governing precedent applied by the court.

The court acknowledged the pending Supreme Court proceeding in Kian, which presented whether trying a defendant charged with a serious felony before a jury of fewer than twelve people violates the Sixth and Fourteenth Amendments. The Second District nevertheless affirmed without staying the case or providing further analysis.

Key Takeaways

  • The Second District affirmed Bell’s judgment in a per curiam opinion.
  • The cited authorities indicate that Bell’s appellate claim concerned a constitutional right to a twelve-person jury.
  • The court applied existing precedent despite acknowledging that the U.S. Supreme Court had granted review of the issue in another Florida case.

Why It Matters

The decision shows that, pending further direction from the U.S. Supreme Court, the Second District continued to follow precedent permitting juries of fewer than twelve members in the circumstances governed by Williams and Serrano-Delgado.

The court’s express reference to Kian flags that the constitutional jury-size question was under active Supreme Court review and could affect similar Florida criminal cases.

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