Advisory Opinion to the Governor re: Implementation of Amendment 4, the Voting Restoration Amendment
Responding to Governor DeSantis's request under article IV, section 1(c), the Florida Supreme Court held that the phrase "completion of all terms of sentence" in article VI, section 4 (Amendment 4) encompasses all legal financial obligations e e fines, restitution, costs, and fees e e imposed in conjunction with an adjudication of guilt, not merely durational periods. In doing so, the Court expressly embraced the "supremacy-of-text principle" for construing Florida constitutional and statutory text, disapproving reliance on framers'/voters' intent as a starting point. Justice Labarga concurred in result but dissented from the Court's rejection of extrinsic evidence of intent.
Key facts
- Governor DeSantis requested an advisory opinion from the Florida Supreme Court regarding the meaning of 'completion of all terms of sentence' in Amendment 4, the Voting Restoration Amendment, which restores voting rights to certain individuals with prior felony convictions.
- The central question was whether 'all terms of sentence' in article VI, section 4 of the Florida Constitution includes only durational prison sentences or also encompasses all legal financial obligations such as fines, restitution, costs, and fees imposed with a conviction.
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Why it matters
Beyond the voting-rights result, the opinion is a significant methodological decision: the Court formally adopts textualism and the "supremacy-of-text principle" for Florida constitutional and statutory interpretation… — full analysis with a trial
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