Blakley v. Florida

Background

A man convicted of sexual battery in Florida was tried after a police officer testified that he refused to make a statement following his arrest and after receiving Miranda warnings. The trial court overruled defense objections to that testimony. A divided Florida District Court of Appeal affirmed the conviction (362 So.2d 309 (1978)), and the case was then presented to the Supreme Court for review.

Reasoning

The Supreme Court denied the petition asking it to review the Florida appellate decision, so the lower-court judgment stands for now. One Justice, joined by another, dissented from the denial. In the dissent they relied on a prior decision, Doyle v. Ohio, which held that using a defendant’s silence after Miranda warnings for impeachment purposes violates due process. The dissenting Justice said the Florida decision conflicts with Doyle and that the conflict is clear enough to justify taking the case and reversing the conviction.

Real world impact

Because the Court declined to hear the case, the Florida conviction remains in effect and the trial court’s allowance of testimony about the defendant’s post-arrest silence is not overturned by this decision. The denial is not a final ruling on the legal dispute; the dissent indicates an unsettled question about whether similar testimony should be allowed under Doyle. Defendants in similar situations in Florida will not get relief from this Supreme Court order, though the issue could return to the high court later.

Dissents or concurrances

A dissenting Justice would have granted review and suggested summary reversal, saying the Florida ruling plainly conflicts with Doyle and that the conviction should be reconsidered.