What Does ''Sufficient Aggravating Circumstances'' Mean ?
In State v. Dixon, 283 So. 2d 1 (Fla. 1973), this Court interpreted the term "sufficient aggravating circumstances" in Florida's capital sentencing scheme to mean one or more such circumstances. See id. at 9 ("When one or more of the aggravating circumstances is found, death is presumed to be the proper sentence unless it or they are overridden by one or more of the mitigating circumstances . . . .").
This Court has explained that "the Legislature is presumed to know the judicial constructions of a law when amending that law, and the Legislature is presumed to have adopted prior judicial constructions of a law unless a contrary intention is expressed." Fla. Dep't of Children & Families v. F.L., 880 So. 2d 602, 609 (Fla. 2004) (emphasis supplied).
Since Dixon, the Legislature has not amended the Florida Statutes to provide that at least two aggravating circumstances must be found to impose a sentence of death.
Therefore, it can be presumed that the Legislature agrees with and has adopted the Dixon Court's interpretation of the term "sufficient aggravating circumstances."