Guzman v. State
The Fourth DCA affirmed Guzman's convictions and life sentences for sexual battery and lewd molestation, rejecting his unpreserved claim that Florida's six-person jury violates the Sixth Amendment under Ramos v. Louisiana, and holding that defense counsel impliedly waived the statutory right to a presentence investigation (PSI) by proceeding to sentencing after the trial court expressly noted Guzman's entitlement to one. Judge Gross wrote separately to explore in depth whether Ramos's originalist reasoning undermines Williams v. Florida's continued vitality, though he agreed Williams remains binding precedent.
Key facts
- Guzman was convicted of sexual battery and lewd molestation and sentenced to life imprisonment in the trial court.
- Guzman appealed his convictions and sentences, raising unpreserved claims that Florida's six-person jury violates the Sixth Amendment and that he was entitled to a presentence investigation (PSI) before sentencing.
- +2 more key facts with a free trial
Why it matters
The PSI-waiver holding is useful for sentencing practitioners because it clarifies the fact-specific line between Harden/White (no waiver found) and Ortiz (clear on-record waiver), establishing that a trial court's mere… — full analysis with a trial
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