Jack R. Sliney v. State of Florida

CourtSupreme Court of Florida
DecidedMay 25, 2023
DocketSC2022-0700
StatusPublished

This text of Jack R. Sliney v. State of Florida (Jack R. Sliney v. State of Florida) is published on Counsel Stack Legal Research, covering Supreme Court of Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Jack R. Sliney v. State of Florida, (Fla. 2023).

Opinion

Supreme Court of Florida ____________

No. SC2022-0700 ____________

JACK R. SLINEY, Appellant,

vs.

STATE OF FLORIDA, Appellee.

May 25, 2023

PER CURIAM.

Three decades ago, then-19-year-old Jack Sliney murdered

George Blumberg during a robbery of Mr. Blumberg’s pawn shop.

Sliney’s conviction and death sentence for the murder became final

in 1998.1 In January 2022, Sliney filed a second successive

postconviction motion under Florida Rule of Criminal Procedure

3.851.2 Sliney challenges the constitutionality of his death

1. Sliney v. State, 699 So. 2d 662, 672 (Fla. 1997), cert. denied, 522 U.S. 1129 (1998).

2. We previously denied Sliney’s initial postconviction motion and first successive postconviction motion. See Sliney v. State, 944 sentence, arguing that the Eighth Amendment should be

understood to categorically preclude the execution of offenders who

were under age 22 at the time of their crimes. The trial court

summarily denied Sliney’s motion, Sliney appealed the ruling to this

Court, and we now affirm. 3

I.

The decision in Roper v. Simmons, 543 U.S. 551 (2005), sets

the baseline here. In Roper, the United States Supreme Court held

that “[t]he Eighth and Fourteenth Amendments forbid imposition of

the death penalty on offenders who were under the age of 18 when

their crimes were committed.” Id. at 578. To get to that holding,

the Court first conducted “a review of objective indicia of consensus,

as expressed in particular by the enactments of legislatures that

have addressed the question.” Id. at 564. Then the Court applied

its “own independent judgment” to conclude that “the death penalty

So. 2d 270, 289 (Fla. 2006); Sliney v. State, 235 So. 3d 310, 310 (Fla. 2018).

3. We have jurisdiction. See art. V, § 3(b)(1), Fla. Const.

-2- is disproportionate punishment for offenders under 18.” Id. at 564,

575.

The Supreme Court identified three differences between

juveniles and adults that, in the Court’s view, “render suspect any

conclusion that a juvenile falls among the worst offenders”:

juveniles’ relative lack of maturity and underdeveloped sense of

responsibility; their increased vulnerability to outside influences

and peer pressure; and their incompletely formed character. Id. at

569-70. And given juveniles’ “diminished culpability,” the Court

reasoned that “the penological justifications for the death penalty

apply to them with lesser force than to adults.” Id. at 571. The

Court acknowledged that “[t]he qualities that distinguish juveniles

from adults do not disappear when an individual turns 18.” Id. at

574. But it concluded that “18 is the point where society draws the

line for many purposes between childhood and adulthood,” and that

is “the age at which the line for death eligibility ought to rest.” Id.

Sliney’s second successive postconviction motion alleges that

under the logic (if not the holding) of Roper, the Eighth Amendment

should be understood to categorically prohibit the execution of any

offender aged 18 through 21 at the time of his crime. Sliney

-3- emphasizes that his motion does not seek reweighing of age as a

mitigator in his case. Instead, Sliney claims to be a member of a

class for whom the death penalty is categorically off limits.

Sliney’s motion purports to raise two claims, each asserting a

reason why his death sentence violates the Eighth Amendment—

whether it would be more accurate to characterize the motion as

raising a single Eighth Amendment claim is something we need not

decide to resolve this appeal. The first claim invokes supposedly

new scientific evidence about brain development to support the

proposition that offenders aged 18 to 21, like juveniles, have

diminished culpability. The alleged “newly discovered evidence”

consists of the 2021 version of the Intellectual Disability Manual

issued by the American Association of Intellectual and

Developmental Disabilities (AAIDD). Sliney says that the manual

raised the age of onset for diagnosing individual disability from 18

to 22. According to Sliney, the manual shows “a firm and

conclusive recognition by the scientific community that there is no

functional difference between the brain of an older adolescent and a

juvenile offender.” Sliney’s second claim alleges that his death

sentence is disproportionate punishment prohibited by the Eighth

-4- Amendment. The basis for this claim is an alleged national

consensus against the death penalty for individuals aged 18

through 21.

The trial court held a Huff 4 hearing to consider these

arguments and to determine whether resolution of Sliney’s motion

would require an evidentiary hearing. The court then summarily

denied Sliney’s claims, concluding that the claims were untimely,

procedurally barred, and substantively precluded by this Court’s

precedent. See, e.g., Branch v. State, 236 So. 3d 981, 987 (Fla.

2018) (“[U]nless the United States Supreme Court determines that

the age of ineligibility for the death penalty should be extended, we

will continue to adhere to Roper.”). This appeal followed.

II.

Florida Rule of Criminal Procedure 3.851(f)(5)(B) authorizes

the trial court to deny a successive postconviction motion without

an evidentiary hearing if “the motion, files, and records in the case

conclusively show that the movant is entitled to no relief.” Sliney

argues that an evidentiary hearing was required in his case and

4. Huff v. State, 622 So. 2d 982 (Fla. 1993).

-5- that the court below erred by summarily denying his motion. We

disagree.

To sustain the trial court’s ruling, we need only explain our

agreement with the court’s conclusion that Sliney’s claims are

untimely. The general rule is that a motion seeking relief under

rule 3.851 must be filed “within 1 year after the judgment and

sentence become final.” Fla. R. Crim. P. 3.851(d)(1). An exception

applies when “the facts on which the claim is predicated were

unknown to the movant or the movant’s attorney and could not

have been ascertained by the exercise of due diligence.” Fla. R.

Crim. P. 3.851(d)(2)(A). A motion traveling under this provision

must be filed within one year of the date such facts become

discoverable through due diligence. Jimenez v. State, 997 So. 2d

1056, 1064 (Fla. 2008).

Sliney filed his motion on January 14, 2022, decades after his

death sentence became final. He argues that the motion is timely

because he filed it within one year of the January 15, 2021, release

of the updated AAIDD manual. Sliney urges us to conclude that the

“new” evidence of the alleged scientific consensus reflected in the

manual transcends long-available studies indicating that brain

-6- development continues beyond age 18. To be clear, Sliney relies on

the publication of the 2021 AAIDD manual to justify the timeliness

of both his “newly discovered evidence” claim and his

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Related

Roper v. Simmons
543 U.S. 551 (Supreme Court, 2005)
Huff v. State
622 So. 2d 982 (Supreme Court of Florida, 1993)
Sliney v. State
699 So. 2d 662 (Supreme Court of Florida, 1997)
Jimenez v. State
997 So. 2d 1056 (Supreme Court of Florida, 2008)
Jack R. Sliney v. State of Florida
235 So. 3d 310 (Supreme Court of Florida, 2018)
United States v. Gonzalez
981 F.3d 11 (First Circuit, 2020)

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