Special Verdict Form Case Examples In Florida
In Brown v. State, 473 So. 2d 1260 (Fla. 1985), the Court held that it was proper for the trial court to refuse the use of special verdict forms which would have indicated whether first-degree murder conviction was based upon premeditated or felony-murder.
In Buford v. State, 492 So. 2d 355 (Fla. 1986), Buford's argument was that in light of various theories of first-degree murder presented to the jury, a special verdict form was required to insure that the jury did not convict him under a theory and factual setting which would prohibit the imposition of the death penalty.
The Court held that a special verdict form is not required to determine whether a defendant's first-degree murder conviction is based upon premeditated murder, felony murder or accomplice liability. Id., at 358.
Further, counsel is not ineffective for failure to anticipate changes in the law. Muhammad v. State, 426 So. 2d 533 (Fla. 1983); Harvey v. Dugger, 656 So. 2d 1253 (Fla. 1995).