lesser offense bar (Florida) · Go Syfert
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lesser offense bar in Florida

12 Florida opinions name it 2 courts 1961–2024 1 in the last five years

The cases below were cited by Florida courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (4)

CaseFollowedCited
State v. Powellgreen
fla · 1996 · cited in 1 Florida opinions naming this issue, 2024–2024
1 sentence

2024Shere has not pointed to any case law, language within the ‘principal in the first degree’ statute, or anything else to demonstrate his claim that section 777.011 requires his judgment to be revised once his codefendant is convicted of a lesser degree of crime.”); see also State v. Powell, 674 So. 2d 731, 733 (Fla. 1996) (ruling that the rule of consistency, which applies when conspirators are tried together, is not applicable in Florida except “when verdicts against one defendant on legally interlocking charges are truly inconsistent”); Eaton v. State, 438 So. 2d 822, 823 (Fla. 1983) (explain

11
Eaton v. Stategreen
fla · 1983 · cited in 1 Florida opinions naming this issue, 2024–2024
1 sentence

2024Shere has not pointed to any case law, language within the ‘principal in the first degree’ statute, or anything else to demonstrate his claim that section 777.011 requires his judgment to be revised once his codefendant is convicted of a lesser degree of crime.”); see also State v. Powell, 674 So. 2d 731, 733 (Fla. 1996) (ruling that the rule of consistency, which applies when conspirators are tried together, is not applicable in Florida except “when verdicts against one defendant on legally interlocking charges are truly inconsistent”); Eaton v. State, 438 So. 2d 822, 823 (Fla. 1983) (explain

11
Eaddy v. Stategreen
fla · 1994 · cited in 1 Florida opinions naming this issue, 2013–2013
1 sentence

2013Where one of the elements of the offense charged remains in doubt, but the defendant is plainly guilty of some offense, the jury is likely to resolve its doubts in favor of conviction.” Beck v. Alabama, 447 U.S. 625, 633-34 , 100 S.Ct. 2382 , 65 L.Ed.2d 392 (1980) (quoting Keeble v. United States, 412 U.S. 205, 212-13 , 93 S.Ct. 1993 , 36 L.Ed.2d 844 (1973)) (emphasis added) (footnote omitted); see also Eaddy v. State, 638 So.2d 22, 25 (Fla.1994) (recognizing that this “Hob-son’s choice” creates enhanced risk of conviction for defendant and holding that, in a death penalty case, defendant was

11
Brown v. Stategreen
fla · 1968 · cited in 1 Florida opinions naming this issue, 1969–1969
1 sentence

1969See Brown v. State, Fla.1968, 206 So.2d 377 .

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Florida. Read the followed side critically anyway.

Also cited on this issue (14)

CaseCitedYears
Potts v. State green
fla · 1982
2 sentences

2019Cf. Potts v. State, 430 So. 2d 900 (Fla. 1982) (relied on similar reasoning to hold that defendant tried separately from co-conspirator is not entitled to raise conviction of co-conspirator for a lesser offense as a bar to defendant’s conviction for a greater offense).

1996Cf. Potts v. State, 430 So.2d 900 (Fla. 1982) (relied on similar reasoning to hold that defendant tried separately from co-conspirator is not entitled to raise conviction of co-conspirator for a lesser offense as a bar to defendant's conviction for a greater offense).

31996–2019
Sanford v. State green
fla · 1918
2 sentences

1983Chikitus v. Shands, 373 So.2d 904 (Fla. 1979); Sanford v. State, 75 Fla. 393 , 78 So. 340 (1918). 414 So.2d at 1140 .

1983Chikitus v. Shands, 373 So.2d 904 (Fla. 1979); Sanford v. State, 75 Fla. 393 , 78 So. 340 (1918). 414 So.2d at 1140 .

31967–1983
Chikitus v. Shands green
fla · 1979
2 sentences

1983Chikitus v. Shands, 373 So.2d 904 (Fla. 1979); Sanford v. State, 75 Fla. 393 , 78 So. 340 (1918). 414 So.2d at 1140 .

1982Chikitus v. Shands, 373 So.2d 904 (Fla. 1979); Sanford v. State, 75 Fla. 393 , 78 So. 340 (1918).

21982–1983
Jalbert v. State green
fla · 1957
2 sentences

1966Jalbert v. State, Fla. 1957, 95 So.2d 589 ." Isaac v. State, Fla.App. 1961, 134 So.2d 38, 39 .

1961Jalbert v. State, Fla.1957, 95 So.2d 589 .

21961–1966
Beck v. Alabama green
scotus · 1980
2 sentences

2013Where one of the elements of the offense charged remains in doubt, but the defendant is plainly guilty of some offense, the jury is likely to resolve its doubts in favor of conviction.” Beck v. Alabama, 447 U.S. 625, 633-34 , 100 S.Ct. 2382 , 65 L.Ed.2d 392 (1980) (quoting Keeble v. United States, 412 U.S. 205, 212-13 , 93 S.Ct. 1993 , 36 L.Ed.2d 844 (1973)) (emphasis added) (footnote omitted); see also Eaddy v. State, 638 So.2d 22, 25 (Fla.1994) (recognizing that this “Hob-son’s choice” creates enhanced risk of conviction for defendant and holding that, in a death penalty case, defendant was

2013Where one of the elements of the offense charged remains in doubt, but the defendant is plainly guilty of some offense, the jury is likely to resolve its doubts in favor of conviction.” Beck v. Alabama, 447 U.S. 625, 633-34 , 100 S.Ct. 2382 , 65 L.Ed.2d 392 (1980) (quoting Keeble v. United States, 412 U.S. 205, 212-13 , 93 S.Ct. 1993 , 36 L.Ed.2d 844 (1973)) (emphasis added) (footnote omitted); see also Eaddy v. State, 638 So.2d 22, 25 (Fla.1994) (recognizing that this “Hob-son’s choice” creates enhanced risk of conviction for defendant and holding that, in a death penalty case, defendant was

12013–2013
Keeble v. United States green
scotus · 1973
2 sentences

2013Where one of the elements of the offense charged remains in doubt, but the defendant is plainly guilty of some offense, the jury is likely to resolve its doubts in favor of conviction.” Beck v. Alabama, 447 U.S. 625, 633-34 , 100 S.Ct. 2382 , 65 L.Ed.2d 392 (1980) (quoting Keeble v. United States, 412 U.S. 205, 212-13 , 93 S.Ct. 1993 , 36 L.Ed.2d 844 (1973)) (emphasis added) (footnote omitted); see also Eaddy v. State, 638 So.2d 22, 25 (Fla.1994) (recognizing that this “Hob-son’s choice” creates enhanced risk of conviction for defendant and holding that, in a death penalty case, defendant was

2013Where one of the elements of the offense charged remains in doubt, but the defendant is plainly guilty of some offense, the jury is likely to resolve its doubts in favor of conviction.” Beck v. Alabama, 447 U.S. 625, 633-34 , 100 S.Ct. 2382 , 65 L.Ed.2d 392 (1980) (quoting Keeble v. United States, 412 U.S. 205, 212-13 , 93 S.Ct. 1993 , 36 L.Ed.2d 844 (1973)) (emphasis added) (footnote omitted); see also Eaddy v. State, 638 So.2d 22, 25 (Fla.1994) (recognizing that this “Hob-son’s choice” creates enhanced risk of conviction for defendant and holding that, in a death penalty case, defendant was

12013–2013
Sanders v. State green
fla · 2006
1 sentence

2007As to the proper application of Ray , the supreme court explained that the analysis in Ray applies only when the court first determines that an instruction on a lesser offense was error, at which point the court is required to assess whether that error is fundamental. 944 So.2d at 206 .

12007–2007
Hicks v. State neutral
fladistctapp · 1982
1 sentence

1983Chikitus v. Shands, 373 So.2d 904 (Fla. 1979); Sanford v. State, 75 Fla. 393 , 78 So. 340 (1918). 414 So.2d at 1140 .

11983–1983
State v. Febre green
fla · 1945
2 sentences

1967Southworth v. State, 1929, 98 Fla. 1184 , 125 So. 345 ; Sanford v. State, 1918, 75 Fla. 393 , 78 So. 340 ; Greene v. City of Gulfport, Fla. 1958, 103 So.2d 115 ; State v. Fegre, 1945, 156 Fla. 149 , 23 So.2d 270 ; *537 Deeb v. State, 1938, 131 Fla. 362 , 179 So. 894 .

1967Southworth v. State, 1929, 98 Fla. 1184 , 125 So. 345 ; Sanford v. State, 1918, 75 Fla. 393 , 78 So. 340 ; Greene v. City of Gulfport, Fla. 1958, 103 So.2d 115 ; State v. Fegre, 1945, 156 Fla. 149 , 23 So.2d 270 ; *537 Deeb v. State, 1938, 131 Fla. 362 , 179 So. 894 .

11967–1967
Southworth v. State green
fla · 1929
2 sentences

1967Southworth v. State, 1929, 98 Fla. 1184 , 125 So. 345 ; Sanford v. State, 1918, 75 Fla. 393 , 78 So. 340 ; Greene v. City of Gulfport, Fla. 1958, 103 So.2d 115 ; State v. Fegre, 1945, 156 Fla. 149 , 23 So.2d 270 ; *537 Deeb v. State, 1938, 131 Fla. 362 , 179 So. 894 .

1967Southworth v. State, 1929, 98 Fla. 1184 , 125 So. 345 ; Sanford v. State, 1918, 75 Fla. 393 , 78 So. 340 ; Greene v. City of Gulfport, Fla. 1958, 103 So.2d 115 ; State v. Fegre, 1945, 156 Fla. 149 , 23 So.2d 270 ; *537 Deeb v. State, 1938, 131 Fla. 362 , 179 So. 894 .

11967–1967
Deeb v. State green
fla · 1937
2 sentences

1967Southworth v. State, 1929, 98 Fla. 1184 , 125 So. 345 ; Sanford v. State, 1918, 75 Fla. 393 , 78 So. 340 ; Greene v. City of Gulfport, Fla. 1958, 103 So.2d 115 ; State v. Fegre, 1945, 156 Fla. 149 , 23 So.2d 270 ; *537 Deeb v. State, 1938, 131 Fla. 362 , 179 So. 894 .

1967Southworth v. State, 1929, 98 Fla. 1184 , 125 So. 345 ; Sanford v. State, 1918, 75 Fla. 393 , 78 So. 340 ; Greene v. City of Gulfport, Fla. 1958, 103 So.2d 115 ; State v. Fegre, 1945, 156 Fla. 149 , 23 So.2d 270 ; *537 Deeb v. State, 1938, 131 Fla. 362 , 179 So. 894 .

11967–1967
Greene v. City of Gulfport green
fla · 1958
1 sentence

1967Southworth v. State, 1929, 98 Fla. 1184 , 125 So. 345 ; Sanford v. State, 1918, 75 Fla. 393 , 78 So. 340 ; Greene v. City of Gulfport, Fla. 1958, 103 So.2d 115 ; State v. Fegre, 1945, 156 Fla. 149 , 23 So.2d 270 ; *537 Deeb v. State, 1938, 131 Fla. 362 , 179 So. 894 .

11967–1967
State Ex Rel. Interlandi v. Petteway neutral
fla · 1934
2 sentences

1966Interlandi v. Petteway, 1934, 114 Fla. 850 , 155 So. 319 ." "A charge of breaking and entering with intent to commit a felony necessarily includes as a lesser offense a violation of Section 810.05, Florida Statutes, F.S.A.

1966Interlandi v. Petteway, 1934, 114 Fla. 850 , 155 So. 319 ." "A charge of breaking and entering with intent to commit a felony necessarily includes as a lesser offense a violation of Section 810.05, Florida Statutes, F.S.A.

11966–1966
Isaac v. State green
fladistctapp · 1961
1 sentence

1966Jalbert v. State, Fla. 1957, 95 So.2d 589 ." Isaac v. State, Fla.App. 1961, 134 So.2d 38, 39 .

11966–1966

Statutes the citing opinions construe

FL § 777.011 (3) FL § 782.04 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

MS 96 (1989–2024) TX 61 (1990–2025) MI 46 (1968–2026) CA 33 (1959–2024) MO 29 (1970–2023) CO 21 (1978–2026) IL 18 (1978–2024) TN 18 (1994–2026) FL 12 (1961–2024) NE 12 (1978–2024) IN 12 (1979–2014) KS 11 (1972–2024) GA 10 (1938–2013) WA 10 (1977–2025) OK 9 (2003–2020) NC 8 (1972–2022) DC 8 (1975–2015) NM 6 (1991–2011) MD 5 (1989–1992) AK 5 (1976–2006) AR 4 (1986–2019) UT 4 (1932–2015) WY 3 (1981–1992) OH 3 (1984–2011) OR 3 (1975–1978) MN 3 (1980–2005) DE 3 (1992–2021) PA 3 (1977–2017) AZ 3 (1984–2025) KY 3 (1991–2023) MT 2 (1983–1999) NJ 2 (1954–1954)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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