Is Suppression Hearing Crucial Stage of a Trial ?

In Muehleman v. State, 503 So. 2d 310, 315 (Fla. 1987), the Court held that a suppression hearing is not a crucial stage of a trial. See also United States v. Raddatz, 447 U.S. 667, 679, 65 L. Ed. 2d 424, 100 S. Ct. 2406 (1980) ("The interests at stake in a suppression hearing are of a lesser magnitude than those in the criminal trial itself. . . . We conclude that the process due at a suppression hearing may be less demanding and elaborate than the protections accorded the defendant at the trial itself."). Therefore, we find no Eighth Amendment violation in this regard. In Muhammed, we determined that reversible error occurred when the trial court afforded "great weight" to the jury's recommendation when that jury did not hear any evidence in mitigation. See id. at 363. The jury instructions in that case informed the jury that their recommendation would be given great weight, see id. at 363 n.9, and the sentencing order specifically stated that the jury's recommendation was given great weight in the final sentencing decision. See id. at 363.