Tate v. State
Florida District Court of Appeal
864 So. 2d 44 (2003)
- Written by Caitlinn Raimo, JD
Facts
Lionel Tate (defendant), a 12-year-old, murdered Tiffany Eunick, a six-year-old. Eunick’s injuries were severe, and it was undisputed that they were not accidental or the result of play fighting. Tate was charged with first-degree murder, which carried a mandatory sentence of life in prison without parole, and felony murder. Tate was offered three years in a juvenile-detention facility and 10 years of probation in exchange for a guilty plea, which he rejected. At the plea hearing, Tate testified that he understood his rejection of the offer, had spoken to his mother, and wished to proceed to trial. The court found Tate’s testimony adequate to determine that Tate understood the consequences of his decision. During trial, expert testimony revealed that Tate had a mental age of approximately three or four years old, had an IQ of approximately 90, and was socially immature for his age. Tate was found guilty of both charges and sentenced to life in prison. Defense counsel requested a post-trial evidentiary hearing to determine whether the plea negotiations were adequately explained to Tate and sought a competency evaluation and hearing, contending that Tate did not understand the consequences of proceeding to trial. The court refused to order the hearing, and Tate appealed.
Rule of Law
Issue
Holding and Reasoning (Stone, J.)
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