Background
After a jury trial, Diana Louise Matthews was convicted of attempted first-degree murder with a firearm. The circuit court sentenced her to thirty years in prison, including a twenty-five-year mandatory minimum.
On appeal, Matthews argued that trying and convicting her before a six-person jury violated her rights under the Sixth and Fourteenth Amendments. She acknowledged that she had not raised the issue in the trial court, and she first presented it on appeal in a supplemental initial brief that the Second District permitted her to file.
The Court’s Holding
The Second District affirmed Matthews’s judgment and sentence. It rejected her contention that the six-person jury constituted harmful fundamental error, explaining that Florida law provides for twelve jurors in capital cases and six in other criminal cases.
The court concluded that Williams v. Florida, 399 U.S. 78 (1970), remained binding precedent and required rejection of Matthews’s constitutional claim. Although the U.S. Supreme Court had granted certiorari in Kian v. Florida and might overrule Williams, the possibility of a future change did not permit the court to disregard controlling law. The court affirmed without discussion as to Matthews’s other arguments.
Key Takeaways
- A six-person jury remains constitutionally permissible in a noncapital Florida criminal case under binding U.S. Supreme Court precedent.
- A grant of certiorari in another case does not displace precedent that remains in force.
- The Second District rejected Matthews’s unpreserved jury-size argument and affirmed her conviction and sentence.
Why It Matters
The decision confirms that Florida courts must continue applying Williams unless and until the U.S. Supreme Court overrules it. Defendants challenging six-person criminal juries therefore cannot obtain relief merely by pointing to the Supreme Court’s pending review of the issue in another case.