People v. Florida

Oscar Quindo Florida (defendant) shared a home with two other men, including Alfonso Ranan, whom Florida was convicted of murdering. Florida and Ranan did not get along. A few days before Ranan died, he and Florida got into a fight, and Ranan hit Florida hard enough to give him a black eye. On the day Ranan died, the two men had been hanging out together at Florida’s relative’s house, but when Florida told Ranan he did not have enough room in his car to give Ranan a ride home, Ranan challenged him to a fight again. They fought and were pulled apart. At home, Ranan initiated another fight, which they settled, and Florida went to bed. Ranan later woke Florida from sleep by grabbing him, shouting obscenities, and challenging him to a fight to the death. Ranan put Florida into a chokehold, but Florida broke free, grabbed a knife, and chased Ranan out of the house. Florida stabbed Ranan and returned inside. Ranan died from the stab wound, and Florida was charged with aggravated murder. Under Guam law, aggravated murder meant murder committed intentionally with premeditation. At trial, Florida moved for acquittal before jury deliberations on the grounds that the people had not proved premeditation, an essential element of the crime. The judge denied Florida’s motion and instructed the jury on premeditation, stating that the amount of time needed for premeditation varied based on the person and circumstances. Florida was found guilty of murder, which did not require premeditation, but not aggravated murder, which did, and he appealed. On appeal, Florida argued that the case never should have gone to the jury because there was no premeditation.