Blackwell v. State
Blackwell argued for the first time on appeal that the trial court committed fundamental error by not requiring the jury to unanimously agree on whether he stole the victim's purse or wallet in support of his petit theft conviction. The Third DCA affirmed, holding that the purse and wallet were alternative means of committing a single theft offense arising from one continuous act at the same time and place, so juror unanimity as to the specific item taken was not required.
Key facts
- Blackwell was convicted of petit theft for taking either a purse or wallet from the victim.
- At trial, the jury was not required to unanimously agree on whether Blackwell took the purse or the wallet, and the verdict form presented these as alternative means of theft.
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Why it matters
This opinion reinforces and applies the well-established alternative-means/unanimity distinction in Florida theft prosecutions, providing a useful framework for practitioners assessing fundamental-error challenges to… — full analysis with a trial
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