Parker v. State
On rehearing, the First DCA affirmed Parker's 53-year sentence for hiring a hitman to kill her child's father, rejecting her claim that the trial court's comparison of her culpability to the shooter's violated her right to individualized sentencing. The court clarified that the Florida Supreme Court's abandonment of 'relative culpability review' in capital proportionality cases (Cruz v. State) does not preclude a sentencing court from considering a codefendant's relative culpability as a valid sentencing factor. The court also reversed several probation conditions, striking a parenting-classes requirement as unrelated to the offense under the Biller/Villanueva test, correcting a GPS-monitoring scrivener's error, and modifying a GED/vocational-training condition to a 'good faith effort' standard, while upholding a no-contact condition covering the victim's child.
Key facts
- Parker was convicted of hiring a hitman to kill her child's father and received a 53-year sentence.
- On rehearing, Parker challenged her sentence, arguing the trial court's comparison of her culpability to the shooter violated her right to individualized sentencing, and challenged several probation conditions as invalid.
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Why it matters
This opinion gives practitioners a useful, citable clarification that Cruz v. State's abolition of capital 'relative culpability review' does not extend to a trial court's ordinary consideration of a codefendant's… — full analysis with a trial
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