In Re Commitment of Cartwright
2004 WL 86180, 870 So.2d 152 (2004)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A legislative rule of evidence, such as one permitting reliable hearsay in a special statutory proceeding for civil commitment, does not violate the state constitution's separation of powers doctrine if the rule is substantively intertwined with the statutory scheme created by the legislature.
Facts:
- John R. Cartwright entered into a plea agreement with the State of Florida for multiple counts of attempted capital sexual battery.
- Pursuant to this agreement, Cartwright was convicted and sentenced to a term of incarceration.
- As Cartwright neared the end of his prison sentence, the State initiated proceedings against him under the Jimmy Ryce Act.
- The purpose of these new proceedings was to have Cartwright involuntarily and civilly committed for treatment as a sexually violent predator.
Procedural Posture:
- The State of Florida filed a petition in a Florida trial court seeking the involuntary civil commitment of John R. Cartwright as a sexually violent predator.
- At trial, the court admitted hearsay evidence regarding Cartwright's past offenses over his objection.
- The trial court instructed the jury on the standard for commitment, rejecting a specific instruction requested by Cartwright regarding 'serious difficulty in controlling behavior.'
- A jury found that Cartwright met the statutory criteria for commitment.
- The trial court entered an order civilly committing Cartwright for long-term control, care, and treatment.
- Cartwright, as the appellant, appealed the commitment order to the District Court of Appeal of Florida, Second District, with the State of Florida as the appellee.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does the provision of Florida's Jimmy Ryce Act that permits the admission of reliable hearsay evidence in civil commitment proceedings violate the Florida Constitution's separation of powers by infringing on the Florida Supreme Court's exclusive rulemaking authority?
Opinions:
Majority - Canady, J.
No, the provision of the Jimmy Ryce Act permitting the admission of hearsay does not violate the Florida Constitution's separation of powers. The court upheld the statute for three primary reasons. First, while rules of evidence can be procedural, the legislature may enact them if they are intertwined with substantive rights. Citing precedent like Booker v. State, which upheld hearsay in capital sentencing, the court found this provision analogous. Second, the hearsay provision is 'intimately related to' the substantive right of the state to commit sexually violent predators, as it is essential to the statutory scheme of considering prior offenses without a full retrial. Third, Florida Rule of Civil Procedure 1.010 explicitly allows the legislature to prescribe procedure in 'special statutory proceedings,' such as those under the Ryce Act, unless a court rule states otherwise, which none does in this case. The court also rejected Cartwright's claims that the commitment violated his plea agreement, reasoning that a criminal plea has no bearing on a subsequent, separate civil proceeding.
Concurring - Northcutt, J.
Yes, but concurring in the result. Judge Northcutt agreed with the final judgment only because he was bound by this court's precedent in cases like Lee v. State. However, he wrote separately to state his personal view that the jury instructions given at trial were inadequate and did not meet the constitutional standard required for civil commitment, aligning his reasoning with the dissenting opinion in a prior Florida Supreme Court case.
Analysis:
This decision reinforces the legislature's authority to craft evidentiary rules for 'special statutory proceedings,' thereby narrowing the judiciary's exclusive rulemaking power in specific contexts. By holding that a procedural rule is permissible if 'intertwined with' a substantive legislative scheme, the court provides a durable framework for upholding laws like the Jimmy Ryce Act. This strengthens the state's ability to civilly commit individuals deemed dangerous by streamlining the evidentiary process. However, the court's certification of the jury instruction issue to the Florida Supreme Court signals continued judicial uncertainty about the precise due process requirements for proving a person's lack of control over their behavior in these types of commitment proceedings.
