Smith v. State of Florida
In a Jimmy Ryce Act civil commitment proceeding, the trial court granted the State summary judgment finding by clear and convincing evidence that Smith's battery and false imprisonment convictions were sexually motivated and thus 'sexually violent offenses.' The Fifth DCA reversed, holding section 394.912(9)(h) requires the sexual motivation to be determined beyond a reasonable doubt, and that a summary judgment court must evaluate the record against the applicable heightened burden. The court rejected Smith's argument that a jury trial is always required to make that determination, holding summary judgment procedure is available under Rule 4.110(a).
Key facts
- Smith was convicted of battery and false imprisonment; the State sought civil commitment under the Jimmy Ryce Act by filing a sexually violent predator proceeding.
- The trial court granted summary judgment for the State, finding by clear and convincing evidence that Smith's convictions were sexually motivated offenses.
- +2 more key facts with a free trial
Why it matters
The opinion is a useful general civil-procedure authority: it collects and applies the principle that summary judgment under the post-2021 federal-style standard must be measured against the substantive burden of proof… — full analysis with a trial
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