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Jason Demetrius Stephens v. State of Florida & SC17-1204 Jason Demetrius Stephens v. Julie L. Jones, etc.

Citation: 238 So. 3d 98Docket: SC17-820

Court: Supreme Court of Florida; January 21, 2018; Florida; State Supreme Court

Original Court Document: View Document

Narrative Opinion Summary

Jason Demetrius Stephens appeals the denial of his motion under Florida Rule of Criminal Procedure 3.851 and seeks a writ of habeas corpus following his death sentence. The appeal and habeas petition were stayed pending the outcome of Hitchcock v. State. After the decision in Hitchcock, Stephens was directed to argue why it should not apply to his cases. The Supreme Court of Florida concluded that Stephens is not entitled to relief, affirming the denial of his motion and denying the habeas corpus petition because Hurst v. Florida does not apply retroactively to his case, as his death sentence became final in 2001. The court cautioned that any rehearing motion rearguing the case will be stricken. Chief Justice Labarga and Justices Quince, Polston, and Lawson concurred, while Justice Pariente concurred in the result but maintained her dissenting views from Hitchcock. The case originated from the Circuit Court in Duval County.

Legal Issues Addressed

Application of Hurst v. Florida Retroactivity

Application: The court determined that Hurst v. Florida does not apply retroactively to cases where the death sentence became final before the Hurst decision.

Reasoning: The Supreme Court of Florida concluded that Stephens is not entitled to relief, affirming the denial of his motion and denying the habeas corpus petition because Hurst v. Florida does not apply retroactively to his case, as his death sentence became final in 2001.

Finality of Death Sentence Judgments

Application: The finality of Stephens's death sentence in 2001 was a critical factor in the court's decision to deny relief based on non-retroactivity of Hurst v. Florida.

Reasoning: Stephens was directed to argue why it should not apply to his cases. The Supreme Court of Florida concluded that Stephens is not entitled to relief, affirming the denial of his motion and denying the habeas corpus petition because Hurst v. Florida does not apply retroactively to his case, as his death sentence became final in 2001.

Judicial Concurrence and Dissenting Opinions

Application: The decision reflects unanimity and dissent within the court, highlighting that while the majority concurred, one justice maintained a dissenting view consistent with prior opinions.

Reasoning: Chief Justice Labarga and Justices Quince, Polston, and Lawson concurred, while Justice Pariente concurred in the result but maintained her dissenting views from Hitchcock.

Procedural Bars in Post-Conviction Relief

Application: The court affirmed the denial of Stephens's motion under Rule 3.851, indicating procedural bars to relief in this post-conviction setting.

Reasoning: Jason Demetrius Stephens appeals the denial of his motion under Florida Rule of Criminal Procedure 3.851 and seeks a writ of habeas corpus following his death sentence.

Staying Proceedings Pending Related Case Outcomes

Application: The appeal and habeas petition for Stephens were stayed pending the outcome of Hitchcock v. State, illustrating the practice of staying proceedings when related cases are under consideration.

Reasoning: The appeal and habeas petition were stayed pending the outcome of Hitchcock v. State.