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State v. Chapman
Citations: 625 So. 2d 838; 1993 WL 368925Docket: 80,691
Court: Supreme Court of Florida; September 23, 1993; Florida; State Supreme Court
Ralph Chapman was convicted of DUI manslaughter and vehicular homicide following an automobile accident that resulted in the death of his passenger. The Fifth District Court of Appeal vacated the vehicular homicide conviction, referencing prior cases, while the state argued for affirmation of both convictions based on a 1988 legislative amendment to Florida Statutes. This amendment clarified that individuals committing multiple offenses in one transaction could face separate convictions unless specific exceptions applied. The Supreme Court of Florida reviewed the case due to a conflict with an earlier decision (Murphy v. State) and ultimately approved the Fifth District's ruling. The Court reaffirmed the principle established in Houser v. State, which determined that DUI manslaughter and vehicular homicide are separate offenses, but a single homicide should not be punished under both statutes. The Court interpreted the 1988 amendment as a limitation on leniency rather than a change to established precedent regarding convictions for a single death. Consequently, the Supreme Court disapproved the Murphy decision and upheld the Fifth District's vacatur of the vehicular homicide conviction. The Justices concurred with this ruling.