Brown v. State of Florida
CourtDistrict Court of Appeal of Florida
Date FiledSeptember 25, 2026
Docket2D2025-2204
StatusPublished
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Full Opinion
DISTRICT COURT OF APPEAL OF FLORIDA
SECOND DISTRICT
WALTER F. BROWN,
Appellant,
v.
STATE OF FLORIDA,
Appellee.
No. 2D2025-2204
September 25, 2026
Appeal from the Circuit Court for Sarasota County; Donna M. Padar,
Judge.
Blair Allen, Public Defender, and Megan Banfield, Assistant Public
Defender, Bartow, for Appellant.
James Uthmeier, Attorney General, Tallahassee, and Allison C. Heim,
Assistant Attorney General, Tampa, for Appellee.
SLEET, Judge.
Walter Brown appeals from his judgment and sentence for
possession of cocaine with the intent to sell or deliver. Brown was
convicted following a jury trial, and he was sentenced to sixty-four
months' imprisonment followed by two years' probation. We affirm.
Brown first argues on appeal that the trial court erred by denying
his motion for judgment of acquittal. We find no merit to this argument
and comment on it no further.
Brown also argues on appeal that the trial court committed
fundamental error by allowing him to be tried for a noncapital offense
using a six-person jury.1 He maintains that section 913.10, Florida
Statutes—which provides that "[t]welve persons shall constitute a jury to
try all capital cases, and six persons shall constitute a jury to try all
other criminal cases"—is unconstitutional on its face. We conclude that
Brown has failed to demonstrate any error, let alone fundamental error,
with regard to this argument. See Serrano-Delgado v. State, 392 So. 3d
251, 253 (Fla. 2d DCA 2024) ("In Williams v. Florida, 399 U.S. 78, 86
(Fla. 1970), the United States Supreme Court held that Florida's use of a
six-person jury does not violate the Sixth or Fourteenth Amendment.
The Court reasoned that no historical evidence shows that a twelve-
person jury was an indispensable component of the Sixth Amendment or
that the Framers intended to require a twelve-person jury. Williams is
binding precedent and 'indisputably remains good law.' " (citation
omitted) (quoting Simpson v. State, 368 So. 3d 513, 520 (Fla. 5th DCA
2023) (Pratt, J., concurring))); see also Jack v. State, 349 So. 3d 925, 927
(Fla. 1st DCA 2022) ("[N]o fundamental error occurred when [a]ppellant
was tried and convicted by a six-person jury on noncapital charges.").
Affirmed.
NORTHCUTT and LaROSE, JJ., Concur.
1 The United States Supreme Court has recently granted a petition
for writ of certiorari to review this issue in Kian v. State, 421 So. 3d 439
(Fla. 4th DCA 2025) (table decision), cert. granted, No. 25-6623, 2026 WL
1718018 (U.S. June 15, 2026).
2
Opinion subject to revision prior to official publication.
3