Spaziano v. Florida (468 U.S. 447)
U.S. Supreme Court · decided July 2, 1984 · Supreme Court Database (Spaeth)
- Citation
- 468 U.S. 447 · 104 S. Ct. 3154
- Decided
- July 2, 1984
- Term
- October Term 1983
- Vote
- 6–3
- Majority author
- Justice Blackmun
- Issue area
- Criminal Procedure
- Disposition
- Affirmed
- Outcome
- Petitioning party lost
- Ideological direction
- Conservative
Opinion excerpt
Justice Blackmun delivered the opinion of the Court. This case presents questions regarding the administration of Florida’s capital sentencing statute. In particular, petitioner challenges the trial court’s failure to instruct the jury on lesser included offenses of capital murder. He also challenges the court’s imposition of a sentence of death when the jury had recommended life. We conclude that on the facts of this case, it was not error for the trial judge to refuse to give the lesser included offense instruction and that there is no constitutional requirement that the jury’s recommendation of life be final. We also reject petitioner’s argument that, as applied in this case, the Florida standards for overriding a jury’s sentencing recommendation are so broad and vague as to violate the constitutional requirement of reliability in capital sentencing. I Petitioner Joseph Robert Spaziano was indicted and tried for first-degree murder. The indictment was brought two years and one month after the alleged offense. Under the Florida statute of limitations in effect at the time of the alleged offense, August 1973, the limitations period for noncapital offenses was two years. Fla. Stat. §932.465(2) (1973). There was no statute of limitations for capital offenses, such as first-degree murder. §932.465(1). The primary evidence against petitioner was given by a witness who testified…
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