[Congressional Record Volume 140, Number 33 (Tuesday, March 22, 1994)]
[Senate]
[Page S]
From the Congressional Record Online through the Government Printing Office [www.gpo.gov]


[Congressional Record: March 22, 1994]
From the Congressional Record Online via GPO Access [wais.access.gpo.gov]

 
              NOMINATION OF CHIEF JUSTICE ROSEMARY BARKETT

  Mr. HATCH. Mr. President, upon review of her judicial record and of 
her testimony before the Judiciary Committee, I have decided that I 
must oppose the nomination of Florida Chief Justice Rosemary Barkett to 
be a judge of the U.S. Court of Appeals for the Eleventh Circuit. I do 
so with regret because I like Chief Justice Barkett, and I consider her 
to be a fine person. But, I do so with the firm view that her record 
establishes that she will substitute her own policy views for the 
written law and take too soft an approach to criminal law enforcement.
  In reaching this conclusion, I stress that no judicial nominee needs 
to agree with my reading of the law, or any other Senator's reading, in 
all or nearly all cases. But, there are just too many cases, across too 
wide a range of subjects, where I believe this nominee stepped well 
past the line of responsible judging. I and other Senators inquired 
about many of these cases at her hearing before the Judiciary 
Committee. Incidentally, I notified Chief Justice Barkett in advance of 
the cases that would be the subject of inquiry. I was not reassured by 
her testimony. Indeed, Chief Justice Barkett herself ultimately 
admitted that she overreached or was careless in a number of important 
opinions.
  For example, in her dissent in University of Miami versus Echarte, 
Chief Justice Barkett voted to strike down statutory caps on 
noneconomic damages in medical malpractice cases. In addition to a 
variety of State law grounds, her dissent also relied upon the Federal 
equal protection clause. Without citing any Federal precedent, she 
asserted:

       I fail to see how singling out the most seriously injured 
     medical malpractice victims for less than full recovery bears 
     any rational relationship to the Legislature's stated goal of 
     alleviating the financial crisis in the medical liability 
     insurance industry.

  In fact, the rational relationship between the means and the goal is 
self-evident and was clearly spelled out by the legislature. One might 
well disagree with caps on noneconomic damages as a policy matter. But, 
Chief Justice Barkett's purported application of rational-basis review 
is a stark overreach and a flagrant misuse of the Federal equal 
protection clause. At her hearing, she acknowledged that she should not 
have relied on that clause.
  In another case, Shriner's Hospital versus Zrillic, the nominee again 
relied on the rational basis standard under the Federal equal 
protection clause--as well as on a variety of State law grounds--in 
striking down a statute. In her opinion, she took the remarkable 
position that ``underinclusive or overinclusive classifications fail to 
meet even the minimal standards of the rational basis test.'' This 
distortion of rational basis review into something akin to strict 
scrutiny clearly flies in the face of equal protection principles set 
forth in nearly 50 years of U.S. Supreme Court precedent.
  Justice Barkett's misreliance on the Federal equal protection clause 
in these two cases is all the more striking to me in light of her 
partial dissent in Foster versus State. There, in seeking to rely on a 
theory of statistical racial discrimination in a challenge to the death 
penalty, she expressly acknowledged that the Federal equal protection 
clause was unavailable to her in light of a Supreme Court decision, 
McCleskey versus Kemp, squarely rejecting her view under the U.S. 
Constitution. Accordingly, in her Foster opinion she only relied on the 
Florida equal protection clause. Yet, she did not recognize the error 
of relying on the Federal Constitution when she wrote her opinions in 
Echarte and Zrillic. Her failure to appreciate in these two opinions 
that Supreme Court precedent foreclosed her reliance on the U.S. 
Constitution deeply troubles me. Supreme Court precedent governs lower 
courts not only when the claim presented is identical to that 
previously rejected by the Supreme Court but also when the basic 
doctrinal principles enunciated by the Supreme Court are applicable to 
a case. The failure to appreciate this opens the door to judicial 
activism--a door, I regret to say, I believe this nominee has 
repeatedly walked through.
  I also find Chief Justice Barkett's reliance on Federal substantive 
due process very troubling. In State versus Saiez, she wrote an opinion 
holding that a State law criminalizing the possession of embossing 
machines capable of counterfeiting credit cards ``violated substantive 
due process under the Fourteenth Amendment to the United States 
Constitution.'' Briefly, let me just say here, this expansive, 
substantive use of the due process clause is insupportable under 
Supreme Court precedent. The nominee testified that she was really 
relying on State due process grounds and her inclusion of the Federal 
due process clause was ``careless''.
  Now, I can accept that, on occasion, a sitting judge may wish to 
phrase an opinion differently, in hindsight, or even believe that he or 
she got an opinion wrong. But tossing into her opinion the Federal 
equal protection clause and the Federal due process clause, on 
occasions where they very clearly do not belong, raises concerns that I 
do not find assuaged by testimony acknowledging this was erroneous. 
These two clauses are among the most powerful tools a judge can use, if 
so inclined, to legislate from the bench. In the case of the equal 
protection clause, virtually every law classifies people into at least 
two classes on some basis. Congress might enact limits on medical or 
product liability, which are subject to equal protection analysis as a 
component of the due process clause of the fifth amendment. States or 
Congress may seek to remove recipients from welfare rolls after a time 
limit of 2 years. A misreliance on Federal equal protection in 
reviewing these laws would lead to their erroneous invalidation. In the 
case of the due process clause, there is a tendency by some judges and 
commentators to read almost anything into it. This is all the more 
troubling because the misuse of these two clauses is not subject to 
limiting principles of judging, but only to the whim of the judge.
  There will be many cases of first impression before the eleventh 
circuit. There will also be many times when precedents must be 
construed, and they may be construed broadly or narrowly. Most 
appellate decisions are not reviewed by the Supreme Court. These 
errors, then, are not merely technical or academic.
  My concern about the nominee's approach to judging is heightened by 
other cases. For example, in a redistricting case (In re 
Constitutionality of Senate Joint Resolution 2G), the Florida Supreme 
Court selected from among six different modifications to a state 
legislative redistricting plan. Writing ``dubitante,'' Justice Barkett 
stated that she was--

     loath to agree to any of the convoluted plans submitted under 
     these hurried circumstances * * * If I had to choose only 
     among those presented, however, I would choose the plan 
     submitted by the NAACP simply because this is the 
     organization that has traditionally represented and promoted 
     the position that advances all minority interests.

  At her hearing, Justice Barkett recognized that this opinion gave a 
clear appearance of partiality, as it expressed a preference for a 
party based on who the party was rather than the merits of that party's 
argument. She stated that she wished she had written her opinion 
differently.
  On an occasional lapse, I am willing to give the benefit of the doubt 
to a nominee. But there are just too many instances in Justice 
Barkett's judicial record--the principal basis for evaluating her 
nomination--of overreaching, and on very significant issues, to leave 
me comfortable with elevating her to the eleventh circuit.
  There are many other cases that concern me. For example, in Stall 
versus State, Chief Justice Barkett joined a dissent striking down a 
State obscenity statute on State law grounds. She also wrote separately 
in an opinion that, again, is sweeping and overbroad.
  There are several problems with this dissent.
  First, her statement that, ``A basic legal problem with the 
criminalization of obscenity is that it cannot be defined'' is flatly 
contradicted by the U.S. Supreme Court's landmark opinion in Miller 
versus California (413 U.S. 15 (1973)), which Chief Justice Barkett 
does not even acknowledge, much less discuss.
  Second, she sweepingly claims that an obscenity law such as the one 
in Florida violates ``every principle of notice and due process in our 
society''--not, I might add, a statement limited to state law 
principles, and, again, contradicted by the Miller decision.
  Third, Chief Justice Barkett's opinion mischaracterizes the Florida 
law in the case: That law does not turn on the ``subjective'' view of a 
handful of law enforcement people and jurors or judges, as she 
incorrectly suggests. The Florida law incorporates the standard set 
forth by the U.S. Supreme Court in Miller. The law bans materials that, 
judged by contemporary community standards, appeal to the prurient 
interest, that depict or describe, in a patently offensive way, 
specifically defined sexual conduct, and that lack serious literary, 
artistic, political, or scientific value. Thus, the role of jurors or 
judges under this law would not be to make their own ``subjective 
definition'' of what is obscene, but rather to discern and apply 
existing community standards.
  Incidentally, while I am pleased that she voted to uphold a Florida 
child pornography statute in a different case, I make two observations. 
First, this does not mitigate her sweeping views about the more general 
subject of obscenity. Second, contrary to her testimony, the child 
pornography statute is a different statute from the one she voted to 
strike down in Stall.
  I have all of these concerns, and have yet to reach the issue of 
criminal law enforcement generally and the issue of the death penalty. 
There is much to say on these subjects.
  With respect to criminal law issues aside from the death penalty, I 
believe that the nominee has too often erroneously come down on the 
side of lawbreakers and against police officers and law enforcement. 
She has exhibited an unduly restrictive view of the Fourth Amendment 
that would hamstring the police, especially with regard to controlling 
drugs.

       [See, e.g., Bostick v. State, 554 So.2d 1153 (Fla. 1989), 
     rev'd, 111 S.Ct. 2382 (1991), on remand, 593 So.2d 494 (Fa. 
     1992); State v. Riley, 511 So.2d 282 (Fla. 1987), rev'd, 488 
     U.S. 445 (1989), on remand, 549 So.2d 673 (Fla. 1989); Cross 
     v. State, 560 So.2d 228 (Fla. 1990); Sarantopoulos v. State 
     (Fla. Dec 9, 1993)].

  For example, in Bostick, a case involving cocaine trafficking, 
Justice Barkett adopted an across-the-board, per se ban on passenger 
searches on intercity buses even though Supreme Court precedent clearly 
called for an analysis of a search's legality based on all of the 
particular circumstances of the search. The U.S. Supreme Court reversed 
her.
  The U.S. Supreme Court also reversed her in the Riley case, where her 
misapplication of precedent would have led to dismissal of charges 
against criminals growing marijuana. In yet another drug case, the 
Court criticized her overbroad reading of precedent.
  In her dissent in a case called Cross, Justice Barkett refused to 
credit the testimony of police officers that they had seen cocaine 
packaged in the same peculiar way on hundreds of occasions in their 
combined 20 years of law enforcement. In so doing, she ignored Florida 
precedent cited by the majority that provided that the observation of 
an experienced policeman of circumstances associated with drugs could 
provide probable cause for an arrest.
  In another dissent, she ignored settled principles enunciated in U.S. 
Supreme Court precedent in finding that someone who was growing 
marijuana in his backyard had his fourth amendment rights violated when 
police, acting on a tip, looked over a 6-foot fence, spotted the 
marijuana plants and then obtained a search warrant. Rather than 
inquiring whether the defendant had an expectation of privacy that was 
objectively reasonable, Chief Justice Barkett simply displayed her 
personal opposition toward what she regarded as overly intrusive law 
enforcement.
  Justice Barkett has also written opinions striking down narrowly 
drawn laws that ban loitering for the purpose of prostitution and drug 
dealing. These opinions are badly flawed and misapply precedent. 
Moreover, they seriously disable communities from preventing harmful 
crime.
  In my view, there are too many other instances where she 
unjustifiably construed criminal statutes in favor of criminals.

       [See, e.g., State v. Bivona, 460 So.2d 469 (Fla. DCA 1984), 
     rev'd, 496 So.2d 130 (Fla. 1986); Gayman v. State, 616 So.2d 
     17 (Fla. 1993).]

  With regard to the death penalty, I appreciate that the nominee has 
voted to uphold the death penalty a number of times. I would expect as 
much in a State with a lawful death penalty and, unfortunately, a great 
deal of violent crime. But as I stated at Justice Barkett's hearing, a 
proper inquiry into a nominee's judicial outlook on the death penalty 
is not ended merely by noting that the nominee has upheld the death 
penalty in a number of cases, where even the most activist of judges 
cannot avoid its imposition. If a nominee exhibits a clear tendency to 
strain for unconvincing escapes from the imposition of the death 
penalty in cases where that penalty is appropriate, then that raises 
concerns in my mind about the nominee's fidelity to the law, no matter 
how many times the nominee may have upheld the death penalty in other 
cases. From my review of her record, I have concluded that Justice 
Barkett clearly exhibits such a tendency.
  Let me further note at this point that one of Justice Barkett's 
dissenting opinions would render the death penalty virtually 
unenforceable, unless imposed on the basis of racial quotas. Her 
partial dissent in Foster versus State, had it been the law of Florida 
when she joined the Florida Supreme Court, would likely have led to a 
different outcome in many, if not virtually all, of the cases where she 
did vote to uphold the death penalty. Indeed, the theory she embraced 
in Foster, until its rejection by the U.S. Supreme Court in 1987, had 
become a principal weapon in the antideath penalty movement's arsenal.
  Overall, I believe that Justice Barkett, in reviewing death 
sentences, views aggravating circumstances too narrowly; construes 
mitigating circumstances too broadly; creates unjustified categorical 
exclusions from death penalty eligibility; subjects the death penalty 
to racial statistical analysis that would paralyze its implementation, 
as I have just discussed; and creates procedural anomalies.
  Let me mention just two of the many cases that concern me. Dougan 
versus State is a 1992 Florida Supreme Court case.
  Dougan was the leader of a group that called itself the Black 
Liberation Army and that, according to the trial judge, had as its 
``apparent sole purpose * * * to indiscriminately kill white people and 
thus start a revolution and a race war.'' One evening in 1974, he and 
four other members of his group, armed with a pistol and a knife, went 
in search of victims. They picked up a white hitchhiker, Steven 
Orlando, drove him to an isolated trash dump, stabbed him repeatedly, 
and threw him to the ground. As Orlando writhed in pain and begged for 
his life, Dougan put his foot on Orlando's head and shot him twice--
once in the chest and once in the ear--killing him instantly. 
Subsequent to the murder, Dougan made several tape recordings bragging 
about the murder, and mailed them to the victim's mother as well as to 
the media. The following excerpt from one of the tapes aptly 
illustrates the content:

       He was stabbed in the back, in the chest and the stomach, 
     ah, it was beautiful. You should have seen it. Ah, I enjoyed 
     every minute of it. I loved watching the blood gush from his 
     eyes.

  The Florida Supreme Court upheld the death penalty for Dougan. 
Justice Barkett and another Justice joined a remarkable and very 
disturbing dissent by Justice McDonald in which she voted to reduce the 
death penalty to life imprisonment, with eligibility for parole in 25 
years.
  I rarely fault a nominee about an opinion the nominee has joined 
rather than written. And I do not hold a nominee to every word or 
phrase in an opinion he or she joins. There is an outlook which 
pervades this dissenting opinion, however, which is so striking and 
disturbing that I believe it is appropriate to consider it in 
evaluating this nomination. This is especially so in light of the fact 
that in many other cases Justice Barkett has written separately, or 
merely stated that she concurred in, or dissented from, the result, 
when another opinion had not suited her.
  Normally, I would summarize this dissent, but I do not want anyone 
listening to think that I am distorting it. Accordingly, I am going to 
read verbatim excerpts from it:

       This case is not simply a homicide case, it is also a 
     social awareness case. Wrongly, but rightly in the eyes of 
     Dougan, this killing was effectuated to focus attention on a 
     chronic and pervasive illness of racial discrimination and of 
     hurt, sorrow, and rejection. Throughout Dougan's life his 
     resentment to bias and prejudice festered. His impatience for 
     change, for understanding, for reconciliation matured to 
     taking the illogical and drastic action of murder. His 
     frustrations, his anger, and his obsession of injustice 
     overcame reason. The victim was a symbolic representation of 
     the class causing the perceived injustices.
       To some extent, [Dougan's] emotions were parallel to that 
     of a spouse disenchanted with marriage, full of discord and 
     disharmony which, because of frustration or rejection, 
     culminate in homicide. We seldom uphold a death penalty 
     involving husbands and wives or lovers, yet the emotion of 
     that hate-love circumstance are somewhat akin to those which 
     existed in this case.
       Such a sentence reduction should aid in an understanding 
     and at least a partial reconciliation of the wounds arising 
     from discordant racial relations that have permeated our 
     society. To a large extent, it was this disease of racial 
     bias and discrimination that infect an otherwise honorable 
     person and contributed to the perpetration of the most 
     horrible of crimes. An approval of the death penalty would 
     exacerbate rather than heal those wounds still affecting a 
     large segment of our society.

  This opinion reeks of a moral relativism and excuse-making that I 
find shocking and unacceptable. As much as I personally like Chief 
Justice Barkett, I find it disturbing that President Clinton would 
nominate someone to a judgeship who applied these views to judicial 
decisions.
  In the October 11, 1992, Sunshine magazine, the following reactions 
to this Dougan dissent are quoted:

       ``How can they compare a cold-blooded, premeditated, 
     torturous crime that's motivated by racial hate and equate 
     that to the emotional circumstances in domestic murders?'' 
     asks prosecutor Chuck Morton, himself a black man, after 
     rereading the Dougan case.
       Adds Tallahassee prosecutor Ray Markey: ``To say that this 
     white victim was a sacrificial lamb and call it a social 
     awareness case--that's scary.''

  The Dougan majority had this to say in response to the dissent that 
Justice Barkett joined:

       We disagree with the dissent that this pitiless murder 
     should be equated with the emotional circumstances often 
     existent in homicides among spouses. While Dougan may have 
     deluded himself into thinking murder justified, there are 
     certain rules by which every civilized society must live. One 
     of these rules must be that no one may take the life of 
     another indiscriminately, regardless of what that person may 
     perceive as a justification.
       Our review must be neutral and objective. This Court 
     recently upheld the death penalty in the indiscriminate 
     killing of two blacks by a white defendant. The circumstances 
     of this case merit equal punishment. To hold that death is 
     disproportionate here would lead to the conclusion that the 
     person who put the bomb in the airplane that exploded over 
     Lockerbie, Scotland, or any other terrorist killer should not 
     be sentenced to death if the crimes were motivated by 
     deepseated philosophical or religious justifications.

  Let me explain why the general attitude and outlook adopted by 
Justice Barkett in that dissent concern me so much. The approach taken 
in that dissent is certainly applicable to others besides Dougan, 
including criminals of all races. Let me note that we have many cases 
in our country of racially motivated, disgusting, violent crimes 
against racial minorities. I do not view the perpetrators of such 
violence as worthy of a lesser penalty on account of their backgrounds 
or personal histories either.
  If a person of any race, ethnic background, or social class 
considering violent or other crimes comes to believe that the judicial 
system views past mistreatment or discrimination against them as 
mitigating the seriousness of the crimes they commit or the penalties 
they face, I believe you undermine the principle of neutral justice and 
seriously reduce the deterrent value of the law. You create, frankly, 
an environment or atmosphere of permissiveness if these kinds of 
reasons can be used to justify lesser sentences. And I am not only 
talking about murder cases, such as the recent Colin Ferguson case on a 
Long Island commuter train. I mean other crimes as well, assault, 
robbery, carjackings.
  Before Senators cast their votes on this nominee, they should read 
the opinions in this Dougan case, along with any other opinions they 
deem relevant. Mr. President, I ask unanimous consent that a copy of 
the Dougan case be included in the Record following my remarks.
  The PRESIDING OFFICER. Without objection, it is so ordered.
  (See exhibit 1.)
  Mr. HATCH. In another case, LeCroy v. State [533 So.2d 750 (Fla. 
1988)], the Florida Supreme Court, by a vote of six to one, affirmed a 
death sentence for two brutal first-degree murders by LeCroy, who was 
17 years and 10 months old when he committed the murders. The court 
noted, among other things that the sentencing judge gave great weight 
to LeCroy's youth but found him mentally and emotionally mature. It 
also noted that Florida statutes clearly provided for some decades that 
17-year-olds charged with capital crimes should be punished as adults. 
Construing U.S. Supreme Court precedent, it ruled that there was no 
constitutional bar to the imposition of the death penalty on those who 
were 17 at the time of the capital offense.
  In her lone dissent, Justice Barkett concluded that the eighth 
amendment of the Federal Constitution prohibited Florida from executing 
those who were under 18 at the time of the crime. Reaching out to 
overturn this death sentence seems to be another clear instance of the 
nominee injecting her own policy preferences for the law. It is an 
unfortunate fact that 16- and 17-year-olds are committing the most 
vicious of adult crimes, including much-noted murders of tourists. If a 
State wishes to treat them as adults when they commit such crimes, then 
the substitution of a judge's personal views for the legislature's 
enactment is wrong. Not surprisingly, the U.S. Supreme Court later 
confirmed that it was the majority in LeCroy, rather than Justice 
Barkett, who had correctly read the Federal Constitution. (See Stanford 
versus Kentucky.)
  I have many other concerns about this nominee--including, for 
example, her openness to pervasive quotas--and many other opinions of 
hers that trouble me. These concerns are outlined in some detail in 
three memoranda on Justice Barkett's cases that I would like to attach 
to my remarks. Mr. President, I request unanimous consent that these 
three memoranda be included in the Record following my remarks.
  The PRESIDING OFFICER. Without objection, it is so ordered.
  (See exhibit 2.)
  Mr. HATCH. Some may claim that those of us who have concerns over 
this nomination have focused on a relatively small number of cases and 
that this is not an appropriate way to evaluate the nominee. I have a 
three-part response to this concern.
  First, a large number of cases of any appellate court are, frankly, 
routine, and I would expect that virtually all judges would rule 
unobjectionably in most cases before them.
  Second, and more importantly, if a small number of cases gives rise 
to large concerns, it is appropriate to base a vote on those cases. For 
example, the flagrant misuse of the Federal equal protection clause and 
the Federal due process clause may have occurred in just a handful of 
cases. But these two constitutional provisions are far too powerful, 
far too open to picking and choosing among democratically enacted 
statutes based on the policy preferences of a judge, for me to be much 
comforted by unobjectionable decisions in numerous other, routine 
cases. A single dissent that would sweepingly invalidate obscenity 
laws, notwithstanding clear U.S. Supreme Court precedent to the 
contrary, is tremendously significant for what it says about a 
nominee's legal outlook in a very important area of law. And it gives 
rise to doubts about whether the nominee will properly apply that 
Supreme Court precedent, especially in light of other opinions that 
give cause for the same concern in other contexts. A series of search 
and seizure opinions, improperly hamstringing the police in significant 
ways--especially in the war on drugs--has an importance beyond the mere 
number of these cases. An opinion, like her partial dissent in Foster, 
that would paralyze enforcement of the death penalty counts more than 
scores of routine death penalty cases. Joinder in an opinion like the 
Dougan dissent speaks volumes about a nominee's outlook on crime and 
personal responsibility.
  I could go on and on, but this leads me to my third point:
  The concerns about this nominee arise from more than a handful of 
cases, and they arise across numerous areas of the law, not just the 
death penalty.
  I therefore have concluded with regret that I cannot in good 
conscience support this nomination.
  I will close by noting that all of the tough-on-crime rhetoric the 
President serves up means less than his actions, including selection of 
judges. Placing more police officers on the street will avail us little 
if judges hamstring them; construe our criminal laws in an unduly 
narrow fashion; or sentence the criminals they do convict with 
unwarranted sympathy for the criminal.
  I urge my colleagues to review the cases and the hearing testimony 
for themselves. I believe they will reach the same conclusion.

                               Exhibit 1

  [Supreme Court of Florida, Jan. 2, 1992, Rehearing Denied April 1, 
                                 1992]

 Jacob John Dougan, Appellant, Versus State of Florida, Appellee, No. 
                                 71755

       Defendant was convicted in the Circuit Court, Duval County, 
     R. Hudson Olliff, J., of homicide. Defendant appealed. The 
     Supreme Court, 343 So.2d 1266, affirmed, and later, 362 So.2d 
     657 vacated sentence and remanded for resentencing. On 
     remand, defendant was again sentenced to death, and the 
     Supreme Court again affirmed, 398 So.2d 439. Subsequently, 
     the Supreme Court, 470 So.2d 697, granted defendant new 
     appeal, affirmed his conviction, vacated death sentence, and 
     remanded for resentencing hearing. On remand, defendant was 
     again sentenced to death. The Supreme Court held that: (1) 
     direction to jury to follow mandate of death penalty statute 
     was not error; (2) finding that aggravating circumstances 
     existed sufficient to warrant imposition of death penalty was 
     not error; (3) finding that mitigating evidence was 
     insufficient to warrant sentence of life imprisonment, rather 
     than death, was not error; and (4) death sentence was not 
     disproportionate.
       Affirmed.
       Kogan, J., concurred in the results only.
       McDonald, J., dissented and filed an opinion in which Shaw, 
     C.J., and Barkett, J., joined.

                          1. Jury 33(5.1)

       Trial court has broad discretion in determining if 
     peremptory challenges exercised by prosecutor are racially 
     motivated. (Per Curiam opinion of three Justices with one 
     Justice concurring in the result)

                        2. Criminal Law 731

       Jury may, in its discretion, decide to grant ``jury 
     pardon'' in deciding defendant's guilt. (Per Curiam opinion 
     of three Justices with one Justice concurring in the result.)

                     3. Criminal Law 1206.1(2)

       Death penalty statutes must restrain and guide sentencing 
     discretion in order to insure that death penalty is not meted 
     out arbitrarily and capriciously. (Per Curiam opinion of 
     three Justices with one Justice concurring in the result.)

                  4. Criminal Law 796, 1206.1(2)

       Death penalty statute, and instructions and recommendation 
     forms based upon it, sets out clear and objective standard 
     for channeling jury's discretion. (Per Curiam opinion of 
     three Justices with one Justice concurring in the result.) 
     West's F.S.A. Sec. 921.141(2).

                        5. Criminal Law 796

       Direction to jury to follow mandate of death penalty 
     statute in determining whether to render advisory sentence of 
     death or live imprisonment was not error; statute, which 
     provides that jury must take into consideration both 
     aggravating and mitigating circumstances and recommend 
     sentence of death if sufficient aggravating circumstances 
     exist and are not outweighed by sufficient mitigating 
     circumstances, sets out clear and objective standard, and 
     allowing jury to disregard statutory directions and guidance 
     would engender arbitrariness and capriciousness in jury 
     recommendations. (Per Curiam opinion of three Justices with 
     one Justice concurring in the result.) West's F.S.A. 
     Sec. 921.141(2).

                        6. Criminal Law 796

       Standard jury instruction on nonstatutory mitigating 
     evidence is not ambiguous and allows jurors to consider and 
     weigh relevant mitigation evidence. (Per Curiam opinion of 
     three Justices with one Justice concurring in the result.)

                     7. Criminal Law 986.2(1)

       Deciding whether particular mitigating circumstances have 
     been established and, if established, weight to be afforded 
     those circumstances lies with trial court, and trial court's 
     decision will not be reversed because appellant reaches 
     opposite conclusion. (Per Curiam opinion of three Justices 
     with one Justice concurring in the result.)

                     8. Homicide 357(3, 7, 11)

       Aggravating factors sufficient to warrant imposition of 
     death penalty had been established where defendant and his 
     companions set out with intent to kill any white person they 
     came upon, defendant and his companions kidnapped and 
     murdered hitchhiker in heinous, atrocious and cruel manner, 
     defendant's killing of victim was committed in cold, 
     calculated, and premeditated manner, and defendant, 
     subsequent to murder, made several tape recordings bragging 
     about murder, which were mailed to victim's mother and to the 
     media. (Per Curiam opinion of three Justices with one Justice 
     concurring in the result.) West's F.S.A. Sec. 921.141(2).

                   9. Homicide 357(3, 4, 7, 11)

       In homicide prosecution, mitigating evidence evidence, and 
     sentence to death, rather than life imprisonment, was 
     required where, although defendant participated in civil 
     rights activities and was active in community, social, 
     health, and welfare work, and codefendants who also 
     participated in murder had received lesser sentences, 
     evidence indicated that murder was committed during 
     kidnapping, that murder was heinous, atrocious and cruel, and 
     that defendant had murdered victim in cold, calculated, and 
     premeditated manner. (Per Curiam opinion of three Justices 
     with one Justice concurring in the result.) West's F.S.A. 
     Sec. 921.141(2).

                    10. Homicide 357(3, 7, 11)

       In homicide prosecution, death was not disproportionate 
     sentence where defendant and his companions set out to murder 
     any white person they encountered, defendant and his 
     companions kidnapped hitchhiker and murdered him in heinous, 
     atrocious and cruel manner, defendant, as leader of group, 
     directed execution of kidnapping and murder in cold, 
     calculated, and premeditated manner, and defendant was not 
     mentally deficient, even though defendant had suffered life 
     of racial prejudice. (Per Curiam opinion of three Justices 
     with one Justice concurring in the result.) West's F.S.A. 
     Sec. 921.141(2).
                                  ____

       James E. Ferguson, II of Ferguson, Stein, Watt, Wallas & 
     Adkins, P.A., Charlotte, N.C., for appellant.
       Robert A. Butterworth, Atty. Gen. and Gary L. Printy, Asst. 
     Atty. Gen., Tallahassee, for appellee.


                               per curiam

       We again review a sentence of death imposed on Jacob John 
     Dougan, Jr., for a homicide committed on June 17, 1974.\1\ 
     This Court affirmed two prior death sentences, but later 
     vacated them and remanded for resentencing; the findings of 
     guilt have been affirmed.\2\
---------------------------------------------------------------------------
     \1\Footnotes at end of article.
---------------------------------------------------------------------------
       The trial judge accurately set forth the facts of this 
     murder in his sentencing order:
       ``The four defendants, Jacob John Dougan, Elwood Clark 
     Barclay, Dwyne Critendon, and Brad W. Evans, were part of a 
     group that termed itself the ``Black Liberation Army'' (BLA), 
     and whose apparent sole purpose was to indiscriminately kill 
     white people and thus start a revolution and racial war.
       ``Dougan was the group's unquestioned leader and it was he 
     who conceived the murderous plan. Apparently he did not have 
     to break down a wall of morality to induce Barclay, 
     Crittendon, and Evans to participate--but it was Dougan's 
     plan--and he pushed it through to murderous finality. The act 
     of Dougan in firing the fatal shots and his leadership were 
     undoubtedly reasons the jury recommended death only for him.
       ``The trial testimony showed that on the evening of June 
     17, 1974, the four defendants and William Hearn (who 
     testified for the State) all set out in a car armed with a 
     pistol and a knife with the intent to kill a ``devil''--the 
     ``devil'' being any white person they came upon under such 
     advantageous circumstances that they could murder him, her, 
     or them.
       ``As they drove around Jacksonville, they made several 
     stops and observed a number of white persons as possible 
     victims, but decided the circumstances were not advantageous 
     and that they might be seen and/or thwarted by witnesses. At 
     one stop, Dougan wrote out a note--which was to be placed on 
     the body of the victim ultimately chosen for death.
       ``Eventually, the five men drove towards Jacksonville 
     Beach, where they picked up a white hitchhiker, 18-year-old 
     Stephen Anthony Orlando. Against Orlando's will and over his 
     protest, they drove him to an isolated trash dump, ordered 
     him out of the car, stabbed him repeatedly, and threw him to 
     the ground. As the 18-year-old youth writhed in pain and 
     begged for his life, Dougan put his foot on Orlando's head 
     and shot him twice--once in the chest and once in the ear--
     killing him instantly.''
       Subsequent to the murder, Dougan made several tape 
     recordings bragging about the murder, which were mailed to 
     the victim's mother as well as to the media. The following 
     excerpt from one of the tapes aptly illustrates the content:
       The reason Stephen was only shot twice in the head was 
     because we had a jive pistol. It only shot twice and then it 
     jammed; you can tell it must have been made in America 
     because it wasn't worth a shit. He was stabbed in the back, 
     in the chest and the stomach, ah, it was beautiful. You 
     should have seen it. Ah, I enjoyed every minute of it. I 
     loved watching the blood gush from his eyes.
       The jury recommended the death sentence by a vote of nine 
     to three. The trial court found three aggravating 
     circumstances and no mitigating circumstances and sentenced 
     Dougan to death. Dougan raises numerous points on appeal, 
     only some of which merit discussion.\3\
       [1] The prosecutor exercised several peremptory challenges 
     against black prospective jurors, and Dougan now argues that 
     he failed to give racially neutral explanations for those 
     excusals. The trial court, however, has broad discretion in 
     determining if peremptory challenges are racially motivated. 
     Reed v. State, 560 So.2d 203 (Fla.), cert. denied,----U.S. --
     --, 111 S.Ct. 230, 112 L.Ed.2d 184 (1990). Our review of the 
     record shows no abuse of discretion in the trial court's 
     acceptance of the prosecutor's explanations of the peremptory 
     challenges. Thus, we find no merit to Dougan's first point on 
     appeal.
       Subsection 921.141(2), Florida Statutes (1987), provides:
       (2) ADVISORY SENTENCE BY THE JURY.--After hearing all the 
     evidence, the jury shall deliberate and render an advisory 
     sentence to the court, based upon the following matters:
       (a) Whether sufficient aggravating circumstances exist as 
     enumerated in subsection (5);
       (b) Whether sufficient mitigating circumstances exist which 
     outweigh the aggravating circumstances found to exist; and
       (c) Based on these considerations, whether the defendant 
     should be sentenced to life imprisonment or death.
       The instructions and jury's recommendation form used in 
     this case tracked the language of the statute. During 
     deliberations, however, the jury asked the court if it could 
     recommend life imprisonment ``in the event that the jury 
     decides that sufficient aggravating circumstances exist to 
     justify a death sentence and that sufficient mitigating 
     circumstances do not exist.'' After conferring with the 
     parties, the court told the jury to answer each question on 
     the recommendation form ``as you deem appropriate from the 
     law and the evidence.'' Dougan now argues that the jury 
     should be allowed to recommend life imprisonment regardless 
     of its findings as to aggravating and mitigating 
     circumstances. We disagree.
       [2, 3] A jury may, in its discretion, decide to grant a 
     ``jury pardon'' in deciding a defendant's guilt. E.g., Amado 
     v. State, 585 So.2d 282 (Fla.1991). On the other hand, 
     ``where discretion is afforded . . . on a matter so grave as 
     the determination of whether a human life should be taken or 
     spared, that discretion must be suitably directed and limited 
     so as to minimize the risk of wholly arbitrary and capricious 
     action.'' Gregg v. Georgia, 428 U.S. 153, 188-89, 96 S.Ct. 
     2909, 2932, 49 L.Ed.2d 859 (1976). As pointed out by the 
     United States Supreme Court, ``there is no . . . 
     constitutional requirement of unfettered sentencing 
     discretion . . . and States are free to structure and shape 
     consideration of mitigating evidence `in an effort to achieve 
     a more rational and equitable administration of the death 
     penalty.''' Boyde v. California, 494 U.S. 370, 110 S.Ct. 
     1190, 1196, 108 L.Ed.2d 316 (1990) (quoting Franklin v. 
     Lynaugh, 487 U.S. 164, 181, 108 S.Ct. 2320, 2331, 101 L.Ed.2d 
     155 (1988)). To that end, death penalty statutes must 
     restrain and guide the sentencing discretion to ensure ``that 
     the death penalty is not meted out arbitrarily and 
     capriciously.'' California v. Ramos, 463 U.S. 992, 999, 103 
     S.Ct. 3446, 3452, 77 L.Ed.2d 1171 (1983). Cf. California v. 
     Brown, 479 U.S. 538, 541, 107 S.Ct. 837, 93 L.Ed.2d 934 
     (1987) (``death penalty statutes [must] be structured so as 
     to prevent the penalty from being administered in an 
     arbitrary and unpredictable fashion.'').
       [4] Under subsection 921.141(2) death may be the 
     appropriate recommendation if, and only if, at least one 
     statutory aggravating factor is established. After an 
     aggravator has been established, any mitigating circumstances 
     established by the evidence must be weighed against the 
     aggravator(s). Florida's death penalty statute, and the 
     instructions and recommendation forms based on it, set out a 
     clear and objective standard for channeling the jury's 
     discretion.
       [5] Dougan's claim that the jury should be allowed to 
     disregard the statutory directions and guidance would 
     engender arbitrariness and capriciousness in jury 
     recommendations. This is improper because [i]t is no doubt 
     constitutionally permissible, if not constitutionally 
     required, for the State to insist that ``the individualized 
     assessment of the appropriateness of the death penalty [be] a 
     moral inquiry into the culpability of the defendant, and not 
     an emotional response to the mitigating evidence.'' Whether a 
     juror feels sympathy for a capital defendant is more likely 
     to depend on that juror's own emotions than on the actual 
     evidence regarding the crime and the defendant. It would be 
     very difficult to reconcile a rule allowing the fate of a 
     defendant to turn on the vagaries of particular jurors' 
     emotional sensitivities with our long-standing recognition 
     that, above all, capital sentencing must be reliable, 
     accurate, and nonarbitary. At the very least, nothing . . . 
     prevents the State from attempting to ensure reliability and 
     nonarbitrariness by requiring that the jury consider and give 
     effect to the defendant's mitigating evidence in the form of 
     a ``reasoned moral response,'' rather than an emotional one. 
     The State must not cut off full and fair consideration of 
     mitigating evidence; but it need not grant the jury the 
     choice to make the sentencing decision according to its own 
     whims or caprice.
       Saffle v. Parks, 494 U.S. 484, 110 S.Ct. 1257, 1262-63, 108 
     L.Ed.2d 415 (1990) (citations omitted). Thus, we find no 
     error in the trial court's directing the jury to follow the 
     mandate of subsection 921.141(2).
       [6] We also find no merit to Dougan's other arguments about 
     the instructions on mitigating evidence. The standard jury 
     instruction on nonstatutory mitigating evidence is not 
     ambiguous and allows jurors to consider and weigh relevant 
     mitigating evidence. Robinson v. State, 574 So.2d 108 (Fla.), 
     cert. denied, ---- U.S. ----, 112 S.Ct. 131, 116 L.Ed.2d 99 
     (1991). Dougan's contention that evidence of no prior 
     criminal history can be rebutted only by convictions is 
     incorrect. Walton v. State, 547 So.2d 622 (Fla. 1989), cert. 
     denied, 493 U.S. 1036, S.Ct. 759, 107 L.Ed.2d 775 (1990).
       The trial court found that three aggravators had been 
     established--committed during a kidnapping; heinous, 
     atrocious, or cruel; and committed in a cold, calculated, and 
     premeditated manner. As nonstatutory mitigating evidence, the 
     court specifically considered Dougan's civil rights 
     activities, his community social, health, and welfare work, 
     his family and personal background, his codefendants' lesser 
     sentences, and the racial unrest at the time of this murder. 
     The court held that, on this record, the evidence did not 
     mitigate the penalty. Now, Dougan claims that the trial court 
     erred both in finding that the aggravators had been 
     established and in not finding that mitigators had been 
     established. We disagree.
       [7-9] Dougan states that the mitigating evidence related to 
     four areas: 1) positive character traits; 2) contribution of 
     racial oppression to the homicide; 3) potential for 
     rehabilitation; and 4) inequality between his sentence and 
     those of his codefendants and argues that the court erred in 
     not finding that mitigators had been established. It is 
     apparent from the judge's written findings that he considered 
     these matters. Based on his evaluation of the evidence, 
     however, he decided that the facts of this case did not 
     support Dougan's contention that these matters constituted 
     mitigating circumstances. Rogers v. State, 511 So.2d 526 
     (Fla. 1987), cert. denied, 484 U.S. 1020, 108 S.Ct. 733, 98 
     L.Ed.2d 681 (1988). Deciding whether particular mitigating 
     circumstances have been established and, if established, the 
     weight afforded it lies with the trial court, and a trial 
     court's decision will not be reversed because an appellant 
     reaches the opposite conclusion. Sireci v. State, 587 So.2d 
     450 (Fla. 1991); Stano v. State, 460 So.2d 890 (Fla. 1984), 
     cert. denied, 471 U.S. 1111, 105 S.Ct. 2347, 85 L.Ed.2d 863 
     (1985). We find no reversible error regarding consideration 
     of the evidence Dougan presented in his attempt to mitigate 
     his sentence.
       We likewise find no error in the trial court's holding 
     three aggravators to have been established. The evidence 
     fully supports finding this murder to have been committed 
     during a kidnapping. The facts also set this murder apart 
     from the norm of killing by illustrating the victim's 
     suffering and Dougan's indifference to the victim's pleas and 
     support finding the heinous, atrocious, or cruel aggravator. 
     Cf. Ponticeli v. State, 593 So.2d 483 (Fla. 1991), and cases 
     cited therein. Finally, the planning and execution of this 
     murder demonstrate the heightened premeditation needed to 
     find it had been committed in a cold, calculated, and 
     premeditated manner. Cf. Cruse v. State, 588 So.2d 983 (Fla. 
     1991); Rogers. As discussed later, Dougan had no colorable 
     claim of any moral or legal justification for this killing.
       [10] Turning to Dougan's final point, we disagree that 
     death is disproportionate in this case. There was no 
     suggestion that Dougan is mentally deficient. To the 
     contrary, he is intelligent and articulate and a leader among 
     men. In fact, he recruited his codefendants while teaching 
     them karate. He knew precisely what he was doing.
       The dissent suggests that because Dougan has suffered a 
     life of racial prejudice and that this murder was related to 
     this, his sentence should be reduced to life. We do not 
     minimize the injustices perpetrated by our society upon the 
     black race. However, it must be noted that Dougan suffered 
     less from the racial discrimination that occurred while he 
     was growing up than many others of his race. Although 
     abandoned by his mother, he was adopted at the age of two and 
     one-half years by loving parents who provided him with a 
     stable environment. Several witnesses said that he was well 
     liked in high school, and he achieved the rank of Eagle 
     Scout. There was no evidence that he suffered any racial 
     discrimination not common to all of the black community.
       We disagree with the dissent that this pitiless murder 
     should be equated with the emotional circumstances often 
     existent in homicides among spouses. While Dougan may have 
     deluded himself into thinking this murder justified, there 
     are certain rules by which every civilized society must live. 
     One of these rules must be that no one may take the life of 
     another indiscriminately, regardless of what that person may 
     perceive as a justification.
       Our review must be neutral and objective. This Court 
     recently upheld the death penalty in the indiscriminate 
     killing of two blacks by a white defendant. Asay v. State, 
     580 So.2d 610 (Fla.), cert. denied, ---- U.S. ----, 112 S.Ct. 
     265, 116 L.Ed.2d 218 (1991). The circumstances of this case 
     merit equal punishment. To hold that death is 
     disproportionate here would lead to the conclusion that the 
     person who put the bomb in the airplane that exploded over 
     Lockerbie, Scotland, or any other terrorist killer should not 
     be sentenced to death if the crime were motivated by deep-
     seated philosophical or religious justifications.
       We have reviewed the other issues Dougan raises\4\ and find 
     no reversible error. Therefore, we affirm the sentence of 
     death.
       It is so ordered.
       OVERTON, GRIMES and HARDING, JJ., concur.
       KOGAN, J., concurs in result only.
       McDONALD, J., dissents with an opinion, in which SHAW, 
     C.J., and BARKETT, J., concur.
       McDONALD, Justice, dissenting.
       This case is unique; it is also a case of contrast. 
     Dougan's counsel describes the events as a tragic aberration 
     while others view them as frightening, inexcusable, and 
     callous. In the entire bizarre series of events leading to 
     and following the murder by ``an unacceptable act of violence 
     upon an unsuspecting white youth,'' Dougan was the leader and 
     the planner.
       Substantial evidence was presented at the last sentencing 
     proceeding to assist the jury, the trial judge, and this 
     Court in determining the appropriate sentence. The jury 
     recommended death,\5\ which the trial judge imposed. He found 
     that the homicide was cold, calculated, and premeditated 
     without any pretense of moral justification, that in its 
     planning it was especially cruel and atrocious and in its 
     execution especially heinous, and that there was a kidnapping 
     to facilitate the crime. The trial judge either rejected 
     mitigating circumstances or found them to be so insignificant 
     that they did not outweigh the aggravating ones.
       It is not our function on review to reweigh the evidence, 
     but, rather, to determine whether the trial judge's findings 
     and conclusions are supported by the record. There is 
     evidence to support the conclusions of the trial judge on the 
     aggravating factors, even though in the mind of Dougan there 
     was a pretense of moral justification for his acts. On the 
     other hand, it is our responsibility to review the totality 
     of the circumstances to determine whether death is 
     appropriate when compared to other death sentences. Adams v. 
     State, 412 So.2d 850 (Fla.), cert. Denied, 459 U.S. 882, 103 
     S.Ct. 182, 74 L.Ed.2d 148 (1982); Brown v. Wainright, 392 
     So.2d 1327 (Fla.), cert. Denied, 454 U.S. 1000, 102 S.Ct. 
     542, 70 L.Ed.2d 407 (1981). We have reduced death sentences 
     to life imprisonment after reviewing both the aggravating and 
     mitigating circumstances as shown in the record and 
     concluding that death is not warranted. E.g., Halliwell v. 
     State, 323 So.2d 557 (Fla.1975).
       Dougan's mother was white and his father, whom he never 
     knew, was black. After Dougan's birth, his mother returned to 
     an all white community where she abandoned her son. Although 
     as much white as black, Dougan was rejected by his white 
     relatives and the white population. Ultimately he was adopted 
     by an understanding and compassionate family which also came 
     from a biracial background. An intelligent person, Dougan was 
     well educated and became a leader in the black community, but 
     throughout his life was confronted with a perception of 
     injustice in race relations. Within the black community he 
     was respected. He taught karate and counseled black youths. 
     When blacks were refused service at a lunch counter, he 
     participated in a sit-down strike in defiance of a court 
     order and was held in contempt of court therefor. This was 
     the only blemish, if it can be called one, on his police 
     record until this homicide.
       The events of this difficult case occurred in tumultuous 
     times. During the time of the late sixties and early 
     seventies, there was great unrest throughout this country in 
     race relations. Duval County, where this homicide occurred, 
     did not escape and was also a place of such unrest. I mention 
     these facts not to minimize what transpired, but, rather, to 
     explain the environment in which the events took place and to 
     evaluate Dougan's mind-set.
       The trial judge was aware of everything I have stated. 
     Indeed, he substantially recited these facts in his 
     sentencing order. His final conclusion was that the grossness 
     of the homicide clearly outweighed any other factor or 
     combination thereof which may have lessened the ultimate 
     penalty. The majority agrees, but I cannot.
       We have said that the death penalty is reserved for those 
     cases where the most aggravating and least mitigating 
     circumstances exist.\6\ We must determine whether Dougan 
     belongs to that class of killers for whom the death penalty 
     is the appropriate punishment. In resolving that issue and 
     mindful of the factors set forth in section 921.141, Florida 
     Statutes (1973), and established case law, we must carefully 
     review what was done, how it was done, why it was done, and 
     what kind of a person did it. How the public views these 
     factors depends to a large extent upon the vantage point or 
     perception of those looking at them. Understandably, in the 
     eyes of the victim, or potential victims, the aggravating 
     factors clearly outweigh the mitigating; in the eyes of the 
     defendant, his friends, and most of those situated in the 
     circumstances of Dougan, the death penalty is not warranted 
     and is disproportionate to the majority of hate slayings, at 
     least where the victim is black and the perpetrator is white.
       Even though we are aware of and sensitive to these 
     contrasting emotions, our review must be neutral and 
     objective. This case is not simply a homicide case, it is 
     also a social awareness case. Wrongly, but rightly in the 
     eyes of Dougan, this killing was effectuated to focus 
     attention on a chronic and pervasive illness of racial 
     discrimination and of hurt, sorrow, and rejection. Throughout 
     Dougan's life his resentment to bias and prejudice festered. 
     His impatience for change, for understanding, for 
     reconciliation matured to taking the illogical and drastic 
     action of murder. His frustrations, his anger, and his 
     obsession of injustice overcame reason.\7\ The victim was a 
     symbolic representative of the class causing the perceived 
     injustices.
       In comparing what kind of person Dougan is with other 
     murderers in the scores of death cases that we have reviewed, 
     I note that few of the killers approach having the socially 
     redeeming values of Dougan. In comparison to Dougan's usual 
     constructive practices, this homicide was indeed an 
     aberration. He has made and, if allowed to live, can make 
     meaningful contributions to society.
       I ask again the question, is this one of the most 
     aggravated and least mitigated cases reserved for the 
     ultimate penalty of death? When considering the totality of 
     the circumstances, but with compassion for and, hopefully, 
     understanding from the family of the victim, I think not. A 
     life sentence makes this penalty more proportionate to what 
     has existed in emotional or other racially caused homicides.
       Such a sentence reduction should aid in an understanding 
     and at least a partial reconciliation of the wounds arising 
     from discordant racial relations that have permeated our 
     society. To a large extent, it was this disease of racial 
     bias and discrimination that infected an otherwise honorable 
     person and contributed to the perpetration of the most 
     horrible of crimes. An approval of the death penalty would 
     exacerbate rather than heal those wounds still affecting a 
     large segment of our society.
       Accordingly, I believe that the death penalty should be 
     vacated and that Dougan's sentence should be reduced to life 
     imprisonment without eligibility for parole for twenty-five 
     years from the date of his incarceration for this murder.
       SHAW, C.J. and BARKETT, J., concur.
                                  ____



                               footnotes

     1. We have jurisdiction. Art. V, Sec. 3(b)(1), Fla. Const.
     2. Barclay v. State, 343 So.2d 1266 (Fla. 1977), cert. 
     denied, 439 U.S. 892, 99 S.Ct. 249, 58 L.Ed.2d 237 (1978); 
     Barclay v. State, 362 So.2d 657 (Fla. 1978); Dougan v. State, 
     398 So.2d 439 (Fla.), cert. denied, 454 U.S. 882, 102 S.Ct. 
     367, 70 L.Ed.2d 193 (1981); Dougan v. Wainwright, 448 So.2d 
     1005 (Fla. 1984); Dougan v. State, 470 So.2d 697 (Fla. 1985), 
     cert. denied, 475 U.S. 1098, 106 S.Ct. 1499, 89 L.Ed.2d 900 
     (1986).
     3. Several issues have been decided adversely to Dougan's 
     contentions: 1) adequacy of instructions on aggravating 
     factors, e.g., Sochor v. State, 580 So.2d 595 (Fla.), cert. 
     granted, -- U.S. --, 112 S.Ct. 436, 116 L.Ed.2d 455 (1991); 
     2) ex post facto application of the cold, calculated, and 
     premeditated aggravating factor, Combs v. State, 403 So.2d 
     418 (Fla. 1981), cert. denied, 456 U.S. 984, 102 S.Ct. 2258, 
     72 L.Ed.2d 862 (1982); and 3) diminution of the jurors' sense 
     of responsibility, e.g., Grossman v. State, 525 So.2d 833 
     (Fla. 1988), cert. denied, 489 U.S. 1071, 109 S.Ct. 1354, 103 
     L.Ed.2d 822 (1989).
     4. The remaining issues are: 1) impermissible appeal to 
     racial bias; 2) refusal to grant change of venue; 3) no 
     probable cause for the arrest; and 4) abdication of 
     prosecutorial function.
     5. The State describes the jury's recommendation of death as 
     basically saying ``that Mother Theresa would get the death 
     penalty for organizing a plan to go out and kidnap an 
     innocent man, torture him and then twice shoot him in the 
     head.''
     6. ``Death is a unique punishment in its finality and in its 
     total rejection of the possibility of rehabilitation. It is 
     proper, therefore, that the Legislature has chosen to reserve 
     its application to only the most aggravated and unmitigated 
     of most serious crimes.'' State v. Dixon, 283 So.2d 1, 7 
     (Fla. 1973), cert. denied, 416 U.S. 943, 94 S.Ct. 1950, 40 
     L.Ed.2d 295 (1974).
     7. To some extent, his emotions were parallel to that of a 
     spouse disenchanted with marriage, full of discord and 
     disharmony which, because of frustration or rejection, 
     culminate in homicide. We seldom uphold a death penalty 
     involving husbands and wives or lovers, yet the emotions of 
     that hate-love circumstance are somewhat akin to those which 
     existed in this case. See, e.g., Ross v. State, 474 So.2d 
     1170 (Fla. 1985); Blair v. State, 406 So.2d 1103 (Fla. 1981). 
     However, if pecuniary gain is a dominant motive in a spousal 
     homicide, we have upheld it. E.g., Buenoano v. State, 527 
     So.2d 194 (Fla. 1988); Byrd v. State, 481 So.2d 468 (Fla. 
     1985), cert. denied, 476 U.S. 1153, 106 S.Ct. 2261, 90

                               Exhibit 2

                    Justice Barkett and Criminal Law

       This memorandum presents opinions by Justice Barkett in the 
     field of criminal law that raise concerns about her 
     decisionmaking in this field. This memorandum generally does 
     not address Justice Barkett's death penalty jurisprudence, 
     which is the subject of a separate memorandum.\1\
---------------------------------------------------------------------------
     Footnotes at end of article.
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                            fourth amendment

       Justice Barkett has a pattern of unduly restrictive search-
     and-seizure decisions that would hamstring the police in 
     their battle against drugs if her views had prevailed.
       Bostick v. State, 554 So.2d 1153 (Fla. 1989), rev'd, 111 S. 
     Ct. 2382 (1991), on remand, 593 So.2d 494 (Fla. 1992)
       Two Broward County Sheriff's officers searching for persons 
     with illegal drugs boarded a bus going from Miami to Atlanta 
     during a stopover in Fort Lauderdale. They had badges and 
     insignia and one had a zipper pouch containing a visible 
     pistol. They asked to inspect the defendant's ticket and 
     identification. The ticket and identification matched. 
     ``However, the two police officers persisted and explained 
     their presence as narcotics agents on the lookout for illegal 
     drugs. In pursuit of that aim, they then requested the 
     defendant's consent to search his luggage.'' Cocaine was 
     discovered in his luggage, and he was arrested and charged 
     with cocaine trafficking.
       The trial judge determined, as a question of fact, that the 
     defendant consented to the search and had been informed of 
     his right to refuse consent. His motion to suppress was 
     denied, and he then pled guilty, reserving his right to 
     appeal the denial of the suppression motion. An appellate 
     court affirmed.
       By a 4 to 3 vote, the Florida Supreme Court, in an opinion 
     by Justice Barkett, ruled that the search violated Bostick's 
     Fourth Amendment rights. Justice Barkett's opinion adopted a 
     per se rule that the police practice of routinely boarding 
     buses to question passengers violates the Fourth Amendment 
     rights of the persons questioned, and that any consent to 
     search is necessarily tainted by this violation. The three 
     dissenters rejected this per se rule; relying on U.S. Supreme 
     Court precedent, they instead stated that the validity of 
     consent was to be determined from the totality of 
     circumstances, and they would have upheld the conviction.
       By a 6 to 3 vote, the U.S. Supreme Court, in an opinion by 
     Justice O'Connor, reversed Justice Barkett's ruling. Florida 
     v. Bostick, 111 S. Ct. 2382 (1991). The Court rejected 
     creation of a per se rule, and instead ruled that the 
     determination whether a particular encounter constitutes a 
     seizure must be made in the light of all the circumstances. 
     The Court found ``dispositive'' the same U.S. Supreme Court 
     precedent that the dissenters to Justice Barkett's opinion 
     had relied on.
       On remand, the Florida Supreme Court, by a 4-3 vote, ruled 
     the search lawful. Justice Barkett, in dissent, concluded 
     that ``Bostick's consent to search was invalid as a product 
     of an unreasonable seizure under the specific facts of this 
     case.''
       This case is noteworthy in several respects:
       1. Justice Barkett initially adopted an overbroad per se 
     rule that would clearly have had the effect (including in the 
     specific case at hand) of vitiating freely given consent to 
     search and of freeing criminals.
       When asked why she did not apply the totality-of-the-
     circumstances test called for under U.S. Supreme Court 
     precedent, Justice Barkett did not answer the question. 
     Instead, she stated that ``search and seizure I think is one 
     of the most difficult areas of the law'' [135:7-8] and 
     suggested (despite clear per se language in her opinion) that 
     it was the U.S. Supreme Court that had ``interpreted'' her 
     opinion to create a per se rule [135:12-14].
       2. Justice Barkett did not follow existing U.S. Supreme 
     Court precedent that both the U.S. Supreme Court and three of 
     her colleagues recognized as dispositive. (The fact that 
     three Supreme Court Justices sided with Justice Barkett does 
     not in any sense validate her position: they were not 
     obligated to adhere to Supreme Court precedent; she was.)
       3. Justice Barkett found occasion to compare the police 
     search method at issue to methods used by ``Nazi Germany, 
     Soviet Russia, and Communist Cuba.''\2\
       At her hearing Justice Barkett denied that she had made any 
     such comparison: ``Senator, I would never compare the conduct 
     of any of our police officers in this country to those of 
     Nazi Germany or Soviet Russia, and I do not think there is 
     any question but that had I made such a comparison, I would 
     not have received the support of many of the rank-and-file 
     officers in my State.'' [136:23-137:3]
       Her opinion shows, however, that Justice Barkett clearly 
     did make such a comparison. The fact that she was able to 
     obtain the support of many police officers in her retention 
     campaign is beside the point (as is the number of prosecutors 
     and law enforcement personnel who opposed her retention).
       Justice Barkett's opinion elicited a rebuke from Florida 
     Attorney General Bob Butterworth (a Barkett supporter). A 
     January 23, 1990, St. Petersburg Times article reported on a 
     speech he gave to the Florida Sheriffs Association:
       ```A pattern appears to be developing, a pattern that 
     should be discouraging to every law-abiding Floridian,' 
     Butterworth said. `During the past two or three years, the 
     Florida Supreme Court has begun to show itself substantially 
     more liberal on crime issues than the U.S. Supreme Court.'
       ``Butterworth said the time may be approaching when 
     Floridians should consider constitutional amendments so 
     accused criminals in Florida don't have rights that aren't 
     available in other states.
       ``Butterworth gave the sheriffs a blow-by-blow look at 
     three Florida Supreme Court rulings that overturned the 
     convictions of defendants in drug cases. Two of the three 
     were written by Justice Rosemary Barkett; the third was an 
     unsigned opinion approved by a 4-3 majority of the justices.
       ``One of the opinions, written by Barkett in November, 
     compared the searches conducted by Broward County sheriff's 
     deputies on commercial buses with the roving patrols and 
     arbitrary searches conducted in Nazi Germany, Soviet Russia 
     and communist Cuba.
       ```It is an insult to the 36,000 police officers in our 
     state to be likened to Nazis,' Butterworth said. `I can 
     assure you that the three Florida law enforcement officers 
     who lost their lives in the line of duty last year were not 
     Nazis. Such language is simply not appropriate, and we should 
     expect more from the highest court in this state.'''

     State v. Riley, 511 So.2d 282 (Fla. 1987), rev'd, 488 U.S. 
     445 (1989), on remand, 549 So.2d 673 (Fla. 1989)
       From a helicopter hovering 400 feet above Riley's property, 
     police detected marijuana growing in a greenhouse. They then 
     obtained a warrant to search the greenhouse, and arrested 
     Riley. The trial court granted Riley's motion to suppress, 
     but the appellate court reversed.
       In a unanimous opinion by Justice Barkett, the Florida 
     Supreme Court ruled that the helicopter surveillance of 
     Riley's greenhouse violated the Fourth Amendment. In 
     determining that Riley had a reasonable expectation of 
     privacy that was invaded by the helicopter surveillance, 
     Justice Barkett sought to distinguish the U.S. Supreme 
     Court's decision in California v. Ciraolo, 476 U.S. 207 
     (1986). In Ciraolo, the Court had held that surveillance from 
     a fixed-wing aircraft flying at 1000 feet did not violate the 
     Fourth Amendment. According to Justice Barkett, ``We simply 
     cannot dismiss as irrelevant the difference between a fixed-
     wing aircraft flying at 1,000 feet and a helicopter circling 
     and hovering at 400 feet so that its occupants can look 
     through an opening in a roof.'' She further stated that 
     ``[s]urveillance by helicopter is particularly likely to 
     unreasonably intrude upon private activities'' and that ``the 
     details observed here from the vantage point of a circling 
     and hovering helicopter could [not] just as easily have been 
     discerned by any person casually flying over the area in a 
     fixed- wing aircraft.''
       The U.S. Supreme Court reversed by a 5-4 vote. The 
     plurality and concurring opinions found Ciraolo 
     indistinguishable (as, apparently, did the authors of the 
     dissenting opinions, since they had also dissented in 
     Ciraolo). In the words of the plurality opinion: ``there is 
     nothing in the record or before us to suggest that 
     helicopters flying at 400 feet are sufficiently rare in this 
     country to lend substance to [Riley's] claim that he 
     reasonably anticipated that his greenhouse would not be 
     subject to observation from that altitude.'' Florida v. 
     Riley, 488 U.S. 445, 451-452 (1989).
       On remand, the Florida Supreme Court remanded to the trial 
     court for further evidentiary development. Riley v. State, 
     549 So.2d 673 (Fla. 1989). Justice Barkett's opinion for the 
     court asserted, ``All nine justices of the United States 
     Supreme Court agreed that the record lacked evidentiary 
     development of Riley's claimed expectation of privacy.'' A 
     separate opinion took the position that Riley's Fourth 
     Amendment claim should be decided adversely to him, without 
     any further evidentiary development.
       A couple aspects of this case warrant attention:
       1. Justice Barkett's attempted distinction of Ciraolo is 
     not faithful to the rationale of Ciraolo. The question is 
     whether an expectation of privacy is reasonable. To determine 
     this, one should look, under the principle of Ciraolo, to 
     whether helicopter flights at an altitude of 400 feet are 
     legal or common. To instead compare what can be seen at 400 
     feet from a helicopter to what can be seen at 1000 feet from 
     a plane is to misapply Ciraolo.
       2. Justice Barkett's suggestion on remand that all 9 U.S. 
     Supreme Court Justices believed that additional evidentiary 
     development was necessary is not accurate. Both the plurality 
     and the concurring opinion clearly believed that the state of 
     the record could be held against Riley. Ultimately, it is 
     probably a question of state law whether further development 
     should be permitted. But the fact that Justice Barkett 
     mischaracterized what the U.S. Supreme Court had said in 
     order to support her remand order is troublesome.
       The White House briefing materials contain a similar 
     distortion: ``The United States Supreme Court narrowly 
     reversed on the question of allocation of the burden of proof 
     in showing a constitutionally unacceptable invasion of 
     privacy.'' [Br. at 23]
       This is the second of the three cases Florida Attorney 
     General Butterworth cited in his January, 1990 speech as part 
     of a pattern of liberal criminal decisions of the Florida 
     Supreme Court.
       Cross v. State, 560 So.2d 228 (Fla. 1990)
       Three detectives spotted Cross in an Amtrak station. Based 
     on her monitoring of them and her lack of luggage for the 
     trip that she was taking, they asked if they could speak with 
     her. She said yes. When the name on her ticket did not match 
     the name on her driver's license, they asked for permission 
     to search her tote bag but advised her that she did not have 
     to consent. She consented. Inside the tote bag, the 
     detectives found a hard baseball-shaped object wrapped in 
     brown tape inside a woman's slip. Having seen cocaine 
     packaged in this manner on ``hundreds of occasions'' in their 
     combined 20 years of law enforcement experience, they then 
     arrested Cross. The contents of the package proved to be 
     cocaine. The trial judge granted Cross's motion to suppress, 
     but the court of appeal (ultimately) reversed.
       By a vote of 5-2, the Florida Supreme Court held that 
     probable cause existed for the arrest. The majority opinion 
     cited Florida precedent holding that the observation of an 
     experienced policeman of circumstances associated with drugs 
     could provide sufficient probable cause. Justice Barkett, 
     dissenting, adopted the reasons stated by a dissenting judge 
     below, who opined that the taped package did not create 
     probable cause. That opinion did not acknowledge, much less 
     credit, the experience of the police officers that cocaine is 
     often packaged in that unusual manner.
       The majority opinion appears clearly correct, and Justice 
     Barkett's dissent appears to reflect an unwarranted 
     reluctance to rely on the experience of police officers 
     (despite precedent warranting such reliance).
       At her hearing, Justice Barkett stated: ``My concern in 
     that case, Senator, was to the quality of the evidence 
     presented. The conclusion of a police officer that it was his 
     experience that this is the way it was does not comport, in 
     my judgment with evidence. A simple conclusory statement does 
     not comport with the requisite evidence.'' [146:22-147:2]
       The police officers' sworn testimony that they had seen 
     cocaine packaged that way ``hundreds of times'' was not 
     ``conclusory.'' Justice Barkett is simply refusing to credit 
     the police officers' testimony.
       Sarantopoulos v. State (Fla. Dec. 9, 1993)
       Having received an anonymous tip that Sarantopoulos was 
     growing marijuana in his backyard, two police officers went 
     to his residence. They entered a neighbor's yard, and one of 
     the officers, standing on his tiptoes, peered over a six-foot 
     high wood fence and spotted marijuana plants. The police then 
     obtained a search warrant and arrested Sarantopoulos. The 
     trial court granted Sarantopoulos's motion to suppress, but 
     the appellate court reversed.
       The Florida Supreme Court, by a 5-2 vote, held that the 
     search was lawful. It reasoned that Sarantopoulos lacked a 
     reasonable expectation of privacy in his backyard, since it 
     was protected from view only from those who remained on the 
     ground and who were unable to see over the six-foot fence.
       Justice Barkett, dissenting, stated, ``I cannot believe 
     that American citizens sitting on porches or in their 
     backyards are not constitutionally protected when government 
     agents, acting only on an anonymous tip, climb on ladders or 
     stretch on tiptoes to peer over privacy fences.''
       The core legal issue under U.S. Supreme Court law--which, 
     under Florida law, governs application of Florida's search-
     and-seizure provision--is whether Sarantopoulos had a 
     reasonable expectation of privacy. Justice Barkett's opinion, 
     unlike the majority's, does not meaningfully address this 
     issue. Instead, it simply reflects a hostility towards what 
     she regards as overly intrusive law enforcement.
       At her hearing, Justice Barkett said that the fact that the 
     search was based on an anonymous tip was ``a factor which I 
     found very significant here.'' [141:20] But this factor is 
     irrelevant to the question whether Sarantopoulos had a 
     reasonable expectation of privacy in the first place; it 
     comes into play only if he did. She also claimed that 
     ``another element [was] whether or not the police were 
     lawfully in the [neighbor's] yard.'' [143:1-2] Again, that 
     question has nothing to do with the prior question whether 
     Sarantopoulos had a reasonable expectation of privacy.
       State v. Wells, 539 So.2d 464 (Fla. 1989), aff'd (but 
     criticized), 495 U.S. 1 (1990)
       Wells was stopped for speeding. When the officer smelled 
     alcohol on his breath, he arrested Wells for DUI. The officer 
     then noticed cash lying on the car's floorboard, and asked 
     Wells to open the car's trunk. Wells agreed to do so, but 
     neither he nor the officer was able to work the trunk's lock. 
     The officer then informed Wells that the car would be 
     impounded. Wells gave permission for the trunk to be forced 
     open and examined. The car was then transported to a 
     facility, and a locked suitcase was found in the trunk. The 
     suitcase was forced open and was found to contain a large 
     amount of marijuana.
       By a vote of 6-1, the Florida Supreme Court, in an opinion 
     originally signed by Justice Barkett but later issued per 
     curiam, held that the search of the suitcase violated Wells' 
     Fourth Amendment rights. Among other things, the court held 
     that the search of the luggage was not permissible under an 
     inventory search theory. Justice Barkett construed a U.S. 
     Supreme Court precedent, Colorado v. Bertine, 479 U.S. 367 
     (1987), as ``mandat[ing] either that all containers will be 
     opened during an inventory search, or that no containers will 
     be opened. There can be no room for discretion.'' Since the 
     police did not have a policy specifically requiring the 
     opening of closed containers, the search of the suitcase was 
     held to violate Bertine.
       The U.S. Supreme Court, while affirming the judgment of the 
     Florida Supreme Court, criticized Justice Barkett's reading 
     of Bertine: ``in forbidding uncanalized discretion to police 
     officers conducting inventory searches, there is no reason to 
     insist that they be conducted in a totally mechanical 'all or 
     nothing' fashion. * * * A police officer may be allowed 
     sufficient latitude to determine whether a particular 
     container should or should not be opened in light of the 
     nature of the search and characteristics of the container 
     itself. * * * The allowance of the exercise of judgment based 
     on concerns related to the purposes of an inventory search 
     does not violate the Fourth Amendment.'' Florida v. Wells, 
     495 U.S. 1, 4 (1990). (This opinion was joined by five 
     Justices; two other Justices also expressly disagreed with 
     Justice Barkett's reading; and no Justice defended it.)
       This case illustrates Justice Barkett's inclination to 
     create mechanical rules that severely limit police discretion 
     and that turn the Fourth Amendment into a straitjacket.
       The White House briefing materials note that the U.S. 
     Supreme Court upheld the decision in Wells, but fail to 
     mention the fact that the Court criticized Justice Barkett's 
     reasoning. [Br. at 22] The White House cites Wells and Riley 
     in support of the claim that Justice Barkett is ``vigilant in 
     upholding the rights of individuals while respecting the 
     critical need for swift and fair law enforcement.'' [Br. at 
     22]


                        PROSECUTORIAL DISCRETION

       Foster v. State, No. 76,639 (Fla. Apr. 1, 1993)
       (This case is addressed more fully in the death penalty 
     memorandum. Its implications for quotas are discussed in the 
     constitutional law memorandum. This memorandum will address 
     its implications for criminal law generally.)
       Foster, two young women, and another man, Lanier, drove to 
     a deserted area where one of the women was to make some money 
     by having sex with Lanier. As Lanier, who was very drunk, was 
     disrobing, Foster suddenly began hitting him and then held a 
     knife to Lanier's throat and sliced his neck. Foster and the 
     women then dragged the still-breathing Lanier into the bushes 
     and covered him with branches and leaves. Foster then took a 
     knife and cut Lanier's spine. Foster and the women then split 
     the money found in Lanier's wallet.
       Foster was convicted of murder and sentenced to death in 
     1975. On resentencing, the trial court, finding three 
     aggravating circumstances, again imposed the death penalty. 
     The Florida Supreme Court, by a 4-3 vote, rejected Foster's 
     claim that his death sentence was a product of racial 
     discrimination against black victims. (The court did remand 
     for resentencing on other grounds.)
       Justice Barkett, dissenting from this racial discrimination 
     ruling, would not accept the majority's determination that 
     Foster's statistical evidence purporting to show that white-
     victim defendants in Bay County were more likely to get the 
     death penalty than black-victim defendants failed to 
     establish a constitutional violation. (Lanier, evidently, was 
     white; Foster's race does not appear to be stated, but 
     newspaper accounts report that he is also white.) Justice 
     Barkett would have relied on the Florida Constitution's Equal 
     Protection Clause to reach a result rejected by the U.S. 
     Supreme Court in McCleskey v. Kemp, 481 U.S. 279 (1987), 
     under the federal Equal Protection Clause. In McCleskey, the 
     Court ruled that a capital defendant claiming a violation of 
     the federal Equal Protection Clause must show the existence 
     of purposeful discrimination and a discriminatory effect on 
     him. According to Justice Barkett:
       (1) The McCleskey standard fails to address the problem of 
     ``unconscious discrimination.''
       (2) Statistical evidence of discriminatory impact in 
     capital sentencing that ``cannot be traced to blatant or 
     overt discrimination'' should establish a violation of 
     Florida's Equal Protection Clause.
       (3) This statistical evidence should be construed broadly 
     to include not only analysis of the disposition of first-
     degree murder cases, ``but also other information that could 
     suggest discrimination, such as the resources devoted to the 
     prosecution of cases involving white victims as contrasted to 
     those involving minority victims, and the general conduct of 
     a state attorney's office, including hiring practices and the 
     use of racial epithets and jokes.'' (Emphasis in italic.)
       (4) The defendant should have the initial burden of showing 
     the strong likelihood that discrimination influenced the 
     decision to seek the death penalty. ``Such discrimination 
     conceivably could be based on the race of the victim or on 
     the race of the defendant.'' Once the initial burden has been 
     met, ``the burden then shifts to the State to show that the 
     practices in question are not racially motivated.''
       In addition to the fact (addressed elsewhere) that Justice 
     Barkett's proposed standard would paralyze implementation of 
     the death penalty, there is no reason why the standard should 
     be limited to death penalty cases; her theory would apply 
     equally to robbery, rape, and all other crimes. There is 
     likewise no reason why Justice Barkett's standard would be 
     limited to cases with white victims; a killer of a male 
     victim, for example, could try to show that sexism pervades 
     the prosecutor's office. As Justice Powell said in rejecting 
     this standard in McCleskey: ``McCleskey's claim, taken to its 
     logical conclusion, throws into serious question the 
     principles that underlie our entire criminal justice 
     system.'' McCleskey, 481 U.S., at 314-315.
       Justice Barkett's proposed standard would effectively 
     impose rigid judicial oversight of prosecutorial 
     decisionmaking.


                         STATUTORY CONSTRUCTION

       State v. Bivona, 460 So.2d 469 (Fla. DCA 1984), rev'd, 496 
     So.2d 130 (Fla. 1986)
       Bivona was arrested for shoplifting in California in June 
     1983. He was also charged by information with a previous bank 
     robbery in Florida. On Florida's request, the State of 
     California held him in jail pending his extradition to 
     Florida, which occurred in August 1983. In January 1984, 
     Bivona filed a motion claiming that the state had failed to 
     bring him to trial within the 180 days required under Florida 
     law. Bivona's motion counted from the time he was first 
     arrested in California, not from the time he was returned to 
     Florida. The trial judge granted the motion and dismissed the 
     charges against him.
       Judge Barkett, then on the district court of appeals, wrote 
     the opinion for a divided (2-1) court affirming the dismissal 
     of charges. The State relied on a section of the law in 
     question, Rule 3.191(b)(1), that read:
       ``A person who is . . . incarcerated in a jail or 
     correctional institution outside the jurisdiction of this 
     State, or who is charged by indictment or information issued 
     or filed under the laws of this State, is not entitled to the 
     benefit of [the 180-day time period] until that person 
     returns or is returned to the jurisdiction of the court 
     within which the Florida charge is pending and until written 
     notice of this fact is filed with the court and served upon 
     the prosecutor.''
       Noting that Bivona had cooperated in being extradited, 
     Judge Barkett ruled that this section ``must be interpreted 
     to apply [only] when a defendant is incarcerated in jails 
     outside the jurisdiction of this state on charges pending in 
     the other state.'' (Emphasis in italic.)
       The Florida Supreme Court unanimously reversed. It found 
     the language of Rule 3.191(b)(1) to be ``without ambiguity'' 
     and criticized Judge Barkett for ``put[ting] a gloss on it, 
     unwarranted by anything that appears in rule 3.191.''
       Gayman v. State, 616 So.2d 17 (Fla. 1993)
       Facts: Gayman was found guilty of petit theft. Because he 
     had two prior convictions for petit theft, the trial court 
     adjudicated him guilty of felony petit theft. It also 
     classified him as a habitual violent felony offender (under 
     the state habitual offender statute) based on a prior felony 
     conviction for aggravated battery. His sentence was enhanced 
     accordingly. A second petitioner, Williams, faced a similar 
     situation; his prior felonies were for burglary and cocaine 
     selling.
       By a 6-1 vote, the Florida Supreme Court rejected Gayman's 
     and Williams' claim that enhancement of a sentence based on a 
     prior conviction constituted double jeopardy.
       Justice Barkett, dissenting in part, opined that it was not 
     sufficiently clear that the Florida legislature specifically 
     intended the double enhancement (as a felony and as a 
     habitual felony offender).
       Justice Barkett fails to demonstrate that the ordinary 
     operation of the Florida statutes would provide anything 
     other than double enhancement. In asserting that the Florida 
     legislature's intent was not sufficiently clear, Justice 
     Barkett is implicitly repudiating the basic principle that 
     legislative intent is reflected in the plain meaning of 
     statutes. This repudiation is a license for judicial 
     activism.


                          ANTI-LOITERING LAWS

       A separate memorandum discusses the serious defects arising 
     from Justice Barkett's opinions that held unconstitutional 
     laws prohibiting loitering for the purpose of prostitution 
     (Wyche) and for the purpose of drug-related activity (E.L. 
     and Holliday). The injury that these rulings inflict on the 
     ability of communities to police themselves bears attention.


                               OBSCENITY

       Justice Barkett's dubiously reasoned position that laws 
     against obscenity violate due process (in Stall) is discussed 
     in a separate memorandum. Justice Barkett uses the 
     hypothetical danger of misapplication of obscenity laws to 
     strike down provisions that safeguard the civilized life of 
     the community.


                               footnotes

     \1\The case summaries in this memorandum are not intended to 
     discourage the reader from reviewing the opinions themselves. 
     Indeed, we encourage such review. In addition, the transcript 
     of Justice Barkett's hearing is available for review in the 
     minority office of the Senate Judiciary Committee.
     \2\The passage in fuller context reads: ``The intrusion upon 
     privacy rights caused by the Broward County police is too 
     great for a democracy to sustain. Without doubt the 
     inherently transient nature of drug courier activity presents 
     difficult law enforcement problems. Roving patrols, random 
     sweeps, and arbitrary searches or seizures would go far to 
     eliminate such crime in this state. Nazi Germany, Soviet 
     Russia, and Communist Cuba have demonstrated all too 
     tellingly the effectiveness of such methods. Yet we are not a 
     state that subscribes to the notion that ends justify 
     means.''
                                  ____


                 Justice Barkett and the Death Penalty

       This memorandum presents Justice Barkett's approach to the 
     death penalty. It is based on a review of over 300 death 
     penalty cases in which Justice Barkett has participated, 
     including every case in which she has written an opinion.\1\
---------------------------------------------------------------------------
     \1\The case summaries in this memorandum are not intended to 
     discourage the reader from reviewing the opinions themselves. 
     Indeed, we encourage such review. In addition, the transcript 
     of Justice Barkett's hearing is available for review in the 
     minority office of the Senate Judiciary Committee.
---------------------------------------------------------------------------
       Part I provides basic background on Florida's death penalty 
     statute and on applicable laws governing death penalty 
     proceedings. Part II examines a broad array of cases that 
     illustrate how Justice Barkett applies these laws. Part III 
     analyzes the oft-made (but little-scrutinized) claim by 
     Justice Barkett's supporters that she has voted to enforce 
     the death penalty in more than 200 cases.
       At the outset, it should be made clear that Justice Barkett 
     has voted to uphold the death penalty on a substantial number 
     of occasions. This only begins the inquiry, however, for one 
     would expect that a judge in a state with a death penalty and 
     many murders committed within it will have many occasions 
     when he or she must uphold the death penalty. But if a 
     nominee exhibits a clear tendency to strain for unconvincing 
     escapes from imposing the death penalty in cases where it is 
     appropriate, that raises a concern about a judge's fidelity 
     to the law, no matter how many times the nominee has upheld 
     the death penalty in other cases. Moreover, as explained 
     below, if Justice Barkett's view in the Foster case had 
     prevailed, it is likely that the death penalty would be 
     effectively repealed.


                      I. FLORIDA DEATH PENALTY LAW

       Under Florida law, Fla. Stat. Sec. 921.141, a defendant who 
     has been found guilty of capital murder then faces a separate 
     sentencing proceeding to determine whether he should be 
     sentenced to death or to life imprisonment. Florida is a so-
     called ``weighing'' state: the death sentence is warranted if 
     the statutory ``aggravating circumstances'' outweigh the 
     ``mitigating circumstances.'' Florida law expressly limits 
     the aggravating circumstances (or ``aggravators'') to the 
     following list of 11:
       (a) the defendant was under sentence of imprisonment when 
     he committed the capital crime;
       (b) the defendant was previously convicted of another 
     capital felony or of a felony involving use or threat of 
     violence;
       (c) the defendant knowingly created a great risk of death 
     to many persons;
       (d) the capital crime was committed while the defendant was 
     committing, or attempting to commit, or fleeing from 
     committing or attempting to commit, a robbery, sexual 
     battery, arson, burglary, kidnapping, aircraft piracy, or 
     bombing;
       (e) the capital crime was committed for the purpose of 
     avoiding or preventing a lawful arrest or effecting an escape 
     from custody;
       (f) the capital crime was committed for pecuniary gain;
       (g) the capital crime was committed to disrupt or hinder 
     the lawful exercise of any government function;
       (h) the capital crime was especially heinous, atrocious, or 
     cruel;
       (i) the capital crime was a homicide and was committed in a 
     cold, calculated, and premeditated manner without any 
     pretense of moral or legal justification;
       (j) the victim was a law enforcement officer engaged in the 
     performance of his official duties; and
       (k) the victim was an elected or appointed public official 
     engaged in the performance of his official duties, and the 
     motive was related to the victim's official capacity.
       Fla. Stat. Sec. 921.141(5). Florida law lists the following 
     seven mitigating circumstances (or ``mitigators''):
       (a) the defendant has no significant history of prior 
     criminal activity;
       (b) the capital crime was committed under the influence of 
     extreme mental or emotional disturbance;
       (c) the victim participated in the defendant's conduct or 
     consented to the act;
       (d) the defendant was merely an accomplice whose 
     participation was relatively minor;
       (e) the defendant acted under extreme duress or the 
     substantial domination of another person;
       (f) the capacity of the defendant to appreciate the 
     criminality of his conduct or to conform his conduct to the 
     requirements of law was substantially impaired; and
       (g) the age of the defendant at the time of the crime. Fla. 
     Stat. Sec. 921.141(6). In addition, under current federal 
     constitutional rulings, any other mitigating evidence is also 
     to be weighed.
       The capital sentencing proceeding has two stages. In the 
     first stage, the jury renders an advisory sentence based on 
     whether sufficient aggravators exist and on whether the 
     mitigators outweigh the aggravators. Fla. Stat. 
     Sec. 921.141(2). In the second stage, the trial judge makes 
     these same determinations. Id. Sec. 921.141(3). But under 
     Florida case law, Tedder v. State, 322 So.2d 908 (Fla. 1975), 
     a jury's recommendation of a life sentence is to be given 
     great weight and can be overturned by the trial judge only if 
     no reasonable person could conclude that death was not 
     warranted.
       A death sentence is entitled to automatic review by the 
     Florida Supreme Court. Fla. Stat. Sec. 921.141(4). Under a 
     1972 provision, anyone who is punished by ``life'' 
     imprisonment may be eligible for parole after 25 years. Fla. 
     Stat. Sec. 775.082.
       Once death-sentenced murderers have lost their direct 
     appeal, they may pursue postconviction relief under state law 
     (as well as federal postconviction relief in the federal 
     courts). Two basic avenues may be pursued. First, a convicted 
     capital murderer may file a motion for postconviction relief 
     in the trial court under Florida Rule of Criminal Procedure 
     3.850. Denial of this motion is then reviewable by the 
     Florida Supreme Court. Second, a convicted capital murderer 
     may file an original action in the Florida Supreme Court for 
     a writ of habeas corpus under Article V, section 3(b)(9) of 
     the Florida Constitution.


           II. JUSTICE BARKETT'S DEATH PENALTY JURISPRUDENCE

       This Part will present cases that illustrate various of the 
     means employed by Justice Barkett to vote against the death 
     penalty. These include: (A) construing aggravators 
     exceedingly narrowly; (B) construing mitigators very broadly; 
     (C) creating categorical exclusions from death penalty 
     eligibility; (D) subjecting the death penalty to racial 
     statistical analyses that would paralyze its implementation; 
     (E) developing procedural anomalies; and (F) failing to 
     provide any reason at all.

             A. Construing Aggravators Exceedingly Narrowly

       When aggravators are given artificially narrow 
     constructions, those who would face the death penalty escape 
     it. Many of Justice Barkett's opinions illustrate a tendency 
     to read the aggravators far too narrowly. For example:
       Cruse v. State, 588 So.2d 983 (Fla. 1991)--
       Cruse loaded an assault rifle, a shotgun, a pistol, and 180 
     rounds of ammunition into his car and began driving to a 
     shopping center. On the way, he fired the shotgun at a 14-
     year-old boy who was playing basketball and then at the boy's 
     parents and brother. At the shopping center, he shot and 
     killed two shoppers who were leaving a grocery store and 
     wounded a third. He then shot at various other customers, 
     killing one and wounding another.
       When Cruse heard sirens approaching, he got back in his car 
     and drove across the street to another shopping center. When 
     Officer Ronald Grogan approached in his police car, Cruse 
     turned, inserted a new clip into his rifle, and fired eight 
     times into the car, killing Officer Grogan.
       Officer Gerald Johnson then entered the parking lot and 
     exited his car. Cruse shot at Officer Johnson and wounded him 
     in the leg. Cruse then headed into the parking lot, searching 
     for the wounded officer. When he found him, he shot Officer 
     Johnson several more times, killing him. As a rescue team 
     attempted to move Officer Grogan's car out of Cruse's line of 
     fire, Cruse fired several shots at them and told them to 
     ``get away from the cop. I want the cop to die.''
       Cruse then entered a store and began firing at people 
     trying to escape. He killed one more and wounded many others. 
     He then found two women hiding in the women's restroom and 
     held one as a hostage for several hours. In all, Cruse killed 
     six people and wounded 10 others.
       Cruse was found guilty of, among other things, six counts 
     of first-degree murder. The jury recommended death on all six 
     counts. The trial court imposed the death penalty for the 
     murders of Officers Grogan and Johnson.
       By a vote of 6 to 1, the Florida Supreme Court affirmed the 
     convictions and the death sentences. In her lone dissent, 
     Justice Barkett voted to reverse the convictions. In 
     addition, she stated that the death sentence was in any event 
     inappropriate for Cruse.
       The basis upon which Justice Barkett would have reversed 
     the convictions was the prosecution's alleged failure to make 
     available to Cruse so-called ``Brady evidence.'' Under the 
     U.S. Supreme Court's ruling in Brady [v. Maryland, 373 U.S. 
     83 (1963)], the prosecution must provide the accused, upon 
     the accused's request, material evidence in its possession 
     that is favorable to the accused. As she stated in your 
     opinion, ``Evidence is material when `there is a reasonable 
     probability that, had the evidence been disclosed to the 
     defense, the result of the proceeding would have been 
     different.'''
       Justice Barkett would have ruled that evidence of the names 
     of two mental health experts whom the prosecution had 
     contacted should have been turned over to Cruse, and that the 
     failure to turn over this evidence required reversal of the 
     convictions and remand for a new trial. In her opinion, she 
     rejected the majority's opinion that this evidence was merely 
     cumulative. In addition, she stated, ``I do not believe that 
     the fact that other experts at trial expressed the same 
     opinion [regarding Cruse's mental state] is a pertinent part 
     of the inquiry of whether or not a Brady violation 
     occurred.''
       In the second part of her dissent, Justice Barkett 
     concluded that even if the convictions were to be upheld, the 
     death sentence was in any event not warranted and should be 
     reduced to life. She would have found that the cold-
     calculated-and-premeditated aggravator was not met. In 
     particular, she concluded that Cruse had the ``pretense of 
     moral or legal justification'' for his killings because ``the 
     evidence shows that Cruse was acting in response to his 
     delusions that people were trying to harm him.''
       Justice Barkett also took the position that even apart from 
     what she saw as a pretense of moral or legal justification, 
     there was insufficient evidence of heightened premeditation 
     in the murders of the two police officers.
       Analysis: Justice Barkett's dissent appears riddled with 
     flaws:
       (1) Her position that it is not pertinent under Brady 
     whether evidence is merely cumulative conflicts with the 
     principle that evidence is material for purposes of Brady 
     only if there is a reasonable probability that disclosure of 
     the evidence would have led to a different result at trial. 
     Merely cumulative evidence is by definition not material. So 
     it appears that the basis upon which she voted to reverse 
     Cruse's convictions is clearly invalid.
       (2) As the majority pointed out, the consensus of the 
     experts who testified was that Cruse's delusions related to a 
     fear that others were trying to turn him into a homosexual, 
     not to a fear of any physical harm. It therefore appears that 
     Justice Barkett's finding of a pretense of moral or legal 
     justification rests on a serious mischaracterization of the 
     evidence.
       (3) What additional facts would be needed to persuade 
     Justice Barkett that Cruse had heightened premeditation? The 
     evidence of heightened premeditation was clear: With respect 
     to the murder of Officer Grogan, the evidence shows that when 
     Officer Grogan approached in his police car, Cruse turned, 
     inserted a new clip into his rifle, and fired eight times 
     into the car, killing Officer Grogan. In addition, as a 
     rescue team attempted to move Officer Grogan's car out of 
     Cruse's line of fire, Cruse fired several shots at them and 
     told them to ``get away from the cop. I want the cop to 
     die.'' With respect to the murder of Officer Johnson, the 
     evidence shows that when Officer Johnson entered the parking 
     lot and exited his car, Cruse shot at him and wounded him in 
     the leg. Cruse then headed into the parking lot, searching 
     for the wounded officer. When he found him, he shot Officer 
     Johnson several more times, killing him.
       McKinney v. State, 579 So.2d 80 (Fla. 1991)--
       A driver of a rental car was shot to death in Miami when he 
     stopped to ask directions. McKinney was convicted of first-
     degree murder (as well as armed robbery, armed kidnapping, 
     and other offenses) and was sentenced to death.
       The Florida Supreme Court, in an opinion by Justice 
     Barkett, voted 6-1 to reverse the death sentence on the 
     ground that the aggravators had not been sufficiently proven. 
     E.g.: ``While it is true that the victim was shot multiple 
     times, a murder is not heinous, atrocious, or cruel without 
     additional facts to raise the shooting to the shocking level 
     required by this factor.''
       Analysis: Justice Barkett's determination that the only 
     evidence supporting the ``heinous, atrocious, or cruel'' 
     aggravator was the number of gunshot wounds ignores the 
     special vulnerabilities that visitors face and the shocking 
     nature of the crime. Indeed, there has been a recent rash of 
     killings of tourists driving rental cars in Miami.
       Porter v. State, 564 So.2d 1060 (Fla. 1990)--
       Porter was the live-in lover of Evelyn Williams from 1985 
     until July 1986. Their relationship was marked by several 
     violent incidents, including Porter's threat to kill Williams 
     and her daughter. Porter left town for a few months, during 
     which time Williams established a relationship with another 
     man, Burrows.
       When Porter returned to town in October 1986, Williams 
     refused to see him. Porter contacted Williams' mother, who 
     told him that Williams did not wish to see him anymore. A few 
     days before the murders, Williams asked to borrow a gun from 
     a friend; the friend declined, but the gun was later missing. 
     During each of the two days before the murder, Porter was 
     seen driving past Williams' home. Then, after drinking 
     heavily, Porter invaded Williams' home, shot her to death, 
     threatened to kill her daughter, and then killed Burrows in a 
     scuffle. Porter pled guilty to the two murders, and was 
     sentenced to death for the murder of Williams.
       By a vote of 5 to 2, the Florida Supreme Court affirmed the 
     death sentence. Barkett, dissenting (with Kogan), opined that 
     in ``almost every other case where a death sentence arose 
     from a lover's quarrel or domestic dispute,'' the court had 
     reversed the death sentence, and that the heightened 
     premeditation aggravator had therefore not been met. She also 
     concluded that Porter's heavy drinking rendered the death 
     sentence disproportionate.
       Analysis: The evidence of heightened premeditation was 
     clear; indeed, Porter basically stalked his victim for two 
     days. Justice Barkett's characterization of the murder as 
     arising from ``lover's quarrel or domestic dispute'' appears 
     inaccurate and beside the point.
       Hodges v. State, 595 So.2d 929 (Fla. 1992)--
       On the morning that Hodges was scheduled for a hearing on a 
     charge of indecent exposure, the 20-year-old clerk who had 
     complained of the indecent exposure was found shot to death 
     next to her car in her store's parking lot. Hodges was 
     convicted and sentenced to death. By a 6-1 vote, the Florida 
     Supreme Court affirmed the death sentence.
       Justice Barkett, dissenting, would have ruled that the two 
     aggravators--witness elimination and cold, calculated, and 
     premeditated killing--were ``so intertwined here that they 
     should be considered as one'' and that, so considered, they 
     did not strongly outweigh the mitigators.
       Analysis: The two aggravators are ``intertwined'' only in 
     the sense that aggravators arising out of the same murderous 
     episode are inevitably intertwined. Witness elimination 
     clearly involves a concern that the ``cold, calculated, and 
     premeditated'' aggravator does not.
       At her hearing, Justice Barkett claimed that her dissent 
     followed (though it did not cite) a case called Cherry v. 
     State, 544 So.2d 184 (Fla. 1989). In Cherry, the court, in an 
     opinion by Justice Barkett, held that the aggravating factor 
     of murder for pecuniary gain improperly duplicated the 
     aggravating factor of murder during the commission of a 
     burglary where the sole purpose of the burglary was pecuniary 
     gain. The central precedent cited in Cherry, however, permits 
     aggravators to be counted separately where they relate to 
     ``separate analytical concepts,'' Provence v. State, 337 
     So.2d 783 (Fla. 1976), which would certainly appear to be the 
     case in Hodges. Justice Barkett's dissent surely does not 
     provide an adequate basis for her conclusion.
       The White House briefing materials brazenly and falsely 
     describe Justice Barkett's dissent in Hodges as ``another 
     excellent example of Justice Barkett's strict adherence to 
     established Florida and U.S. death penalty jurisprudence.'' 
     [Br. at 25]

                B. Construing mitigators too expansively

       In many cases, Justice Barkett appears to give undue weight 
     to alleged mitigating evidence or to rely on such evidence to 
     contend that the death penalty is somehow disproportionate to 
     the crime. She appears too ready to adopt the view that 
     society, or racism, or deprivation, mitigates responsibility 
     for the horrific crime that the defendant has committed.
       Dougan v. State, 595 So.2d 1 (Fla. 1992)--
       Dougan was the leader of a group that called itself the 
     Black Liberation Army and that, according to the trial judge, 
     had as its ``apparent sole purpose . . . to indiscriminately 
     kill white people and thus start a revolution and a race 
     war.'' He conceived a plan for his group to kill a 
     ``devil''--i.e., ``any white person they came upon under such 
     advantageous circumstances that they could murder him.'' One 
     evening in 1974, he and four other members of his group, 
     armed with a pistol and a knife, picked up a white 
     hitchhiker, drove him to a trash dump, stabbed him 
     repeatedly, and threw him to the ground. ``As the 18-year-old 
     youth writhed in pain and begged for his life, Dougan put his 
     foot on [the youth's] head and shot him twice--once in the 
     chest and once in the ear.'' Later, Dougan made several tape 
     recordings bragging about the murder, and mailed them to the 
     victim's mother as well as to the media. The following tape 
     excerpt was said to be illustrative of the tapes' content: 
     ``He [the youth] was stabbed in the back, in the chest and 
     the stomach, ah, it was beautiful. You should have seen it. 
     Ah, I enjoyed every minute of it. I loved watching the blood 
     gush from his eyes.'' (Emphasis in italics.)
       Dougan's case had been considered on the merits five 
     previous times by the Florida Supreme Court. The court had 
     affirmed two prior sentences but later vacated them and 
     remanded for resentencing. On the most recent resentencing, 
     the jury recommended death, and the trial court found three 
     aggravating circumstances and no mitigating circumstances and 
     therefore sentenced Dougan to death.
       The Florida Supreme Court affirmed the death sentence. The 
     plurality rejected a slew of arguments, including the claim 
     that the death penalty was disproportionate under the 
     circumstances.
       Justice Barkett joined a dissent written by Justice 
     McDonald that would have held the death penalty 
     disproportionate. The dissent made the following remarkable 
     observations:
       1. ``This case is not simply a homicide case, it is also a 
     social awareness case. Wrongly, but rightly in the eyes of 
     Dougan, this killing was effectuated to focus attention on a 
     chronic and pervasive illness of racial discrimination and of 
     hurt, sorrow, and rejection. Throughout Dougan's life his 
     resentment to bias and prejudice festered. His impatience for 
     change, for understanding, for reconciliation matured to 
     taking the illogical and drastic action of murder. His 
     frustrations, his anger, and his obsession of injustice 
     overcame reason. The victim was a symbolic representation of 
     the class causing the perceived injustices.'' 595 So.2d, at 
     7-8 (emphasis in italics).
       2. ``To some extent, [Dougan's] emotions were parallel to 
     that of a spouse disenchanted with marriage, full of discord 
     and disharmony which, because of frustration or rejection, 
     culminate in homicide. We seldom uphold a death penalty 
     involving husbands and wives or lovers, yet the emotion of 
     that hate-love circumstance are somewhat akin to those which 
     existed in this case.'' 595 So.2d at 7 n. 7.
       3. ``The events of this difficult case occurred in 
     tumultuous times. During the time of the late sixties and 
     early seventies, there was great unrest throughout this 
     country in race relations. . . . I mention these facts not to 
     minimize what transpired, but, rather, to explain the 
     environment in which the events took place and to evaluate 
     Dougan's mind-set.'' 595 So.2d, at 7 (emphasis in italics).
       4. ``There is evidence to support the conclusions of the 
     trial judge on the aggravating factors, even though in the 
     mind of Dougan there was a pretense of moral justification 
     for his acts.'' 595 So.2d, at 6 (emphasis in italics).
       5. ``Understandably, in the eyes of the victim, or 
     potential victims, the aggravating factors clearly outweigh 
     the mitigating; in the eyes of the defendant, his friends, 
     and most of those situated in the circumstances of Dougan, 
     the death penalty is not warranted and is disproportionate to 
     the majority of hate slayings, at least where the victim is 
     black and the perpetrator is white. Even though we are aware 
     of and sensitive to these contrasting emotions, our review 
     must be neutral and objective.'' 595 So.2d, at 7 (emphasis in 
     italics). (The dissent proceeds directly from here to the 
     first passage quoted above.)
       6. ``In comparing what kind of person Dougan is with other 
     murderers in the scores of death cases that we have reviewed, 
     I note that few of the killers approach having the socially 
     redeeming values of Dougan.'' 595 So.2d, at 8 (emphasis 
     added). (This apparently refers to the dissent's earlier 
     observations that Dougan was ``intelligent,'' ``well 
     educated,'' ``a leader in the black community,'' ``taught 
     karate and counseled black youths,'' and once ``participated 
     in a sit-down strike in defiance of a court order'' at a 
     lunch counter that refused service to blacks.)
       Analysis: (1) The October 11, 1992, Sunshine magazine 
     quoted two prosecutors' responses to the dissent that Justice 
     Barkett joined:
       ``'How can they compare a cold-blooded, premeditated, 
     torturous crime that's motivated by racial hate and equate 
     that to the emotional circumstances in domestic murders?' 
     asks prosecutor Chuck Morton, himself a black man, after 
     rereading the Dougan case.
       ``Adds Tallahassee prosecutor Ray Markey: `To say that this 
     white victim was a sacrificial lamb and call it a social 
     awareness case--that's scary.'''
     In the words of the plurality, ``While Dougan may have 
     deluded himself into thinking this murder justified, there 
     are certain rules by which every civilized society must live. 
     . . . To hold that death is disproportionate here would lead 
     to the conclusion that the person who put the bomb in the 
     airplane that exploded over Lockerbie, Scotland, or any other 
     terrorist killer should not be sentenced to death if the 
     crime were motivated by deep- seated philosophical or 
     religious justifications.'' 595 So.2d, at 6.
       (2) While Justice Barkett did not author the dissent, she 
     signed onto it in its entirety. The fact that she would join 
     such an opinion speaks volumes, especially since she 
     regularly writes separately when she has a different view.
       At her hearing, Justice Barkett stated that she had taken a 
     position in Dougan at one point that was ``different from the 
     one I took ultimately in the dissent. It is a very close 
     case. I cannot quarrel with a conclusion which would have 
     found it the other way. I cannot quarrel with the majority in 
     that case.'' [74:10-15]
       This comment is troubling in several respects: (1) What 
     happens in conference is confidential. To engage in self-
     serving, selective disclosure of confidences is to abuse the 
     process. (2) If Justice Barkett found the dissent so 
     persuasive that she abandoned a previously held position, 
     that exacerbates the concerns that Dougan raises. (3) How can 
     she say that she cannot quarrel with the majority? She did 
     quarrel with it: she dissented. If she is saying that she 
     cannot express a reasoned argument against the majority, then 
     on what basis did she dissent?
       Wickham v. State, 593 So.2d 191 (Fla. 1991)--
       In March 1986, Wickham was driving with family and friends 
     when they discovered that they were low on money and gas. 
     Wickham decided to obtain money through robbery. His group 
     tricked a passing motorist into stopping to examine their 
     car, and Wickham then pointed a gun at him. When the motorist 
     attempted to return to his car, Wickham shot him in the back, 
     and then again in the chest. When the victim pled for his 
     life, Wickham shot him twice in the head. Wickham then 
     rummaged through the victim's pockets and found $4.05. At 
     trial, the jury convicted and recommended death. The trial 
     judge found six aggravating circumstances and no mitigating 
     circumstances, and sentenced Wickham to death.
       The Florida Supreme Court affirmed the death sentence by a 
     4 to 2 vote, with Justices Barkett and McDonald dissenting. 
     According to Justice Barkett's dissent, ``If the death 
     penalty is supposed to be reserved for the most heinous of 
     crimes and the most culpable of murderers, Jerry Wickham does 
     not seem to qualify. . . . At the time he committed this 
     senseless murder, Jerry Wickham was a forty-year-old mentally 
     deficient, socially maladjusted individual who had been 
     institutionalized for almost his entire life.'' 593 So.2d, at 
     194-195.
       Analysis: (1) Wickham and Dougan, read together, are 
     especially revealing: Wickham was ``mentally deficient''; 
     Dougan was ``intelligent'' and ``well educated.'' Wickham was 
     ``socially maladjusted''; Dougan was socially well-adjusted 
     (``a leader in the black community,'' ``respected,'' etc.). 
     Remarkably, the very qualities that Justice Barkett sees as 
     somehow sparing Wickham from the death penalty, when 
     converted into their opposites, manage to spare Dougan. (2) 
     Justice Barkett's tendency to find unjustified mitigation for 
     violent crime is reflected in the following passage from her 
     dissent: ``In early 1966, at the age of twenty-two, [Wickham] 
     was permanently discharged from the mental hospital with no 
     directions, no support, and no medication. Not surprisingly, 
     seven months later he attempted to rob a cab driver, shooting 
     him in the process.'' 593 So.2d, at 195 (emphasis in 
     italics).
       Hayes v. State, 581 So.2d 121 (Fla. 1991)--
       In the course of an evening consuming beer, cocaine, and 
     marijuana, Hayes and two friends conspired to rob and shoot a 
     taxicab driver in order to raise money to buy more cocaine. 
     Hayes volunteered to do the shooting. Carrying out their 
     plan, they borrowed a gun, then called a taxicab. During the 
     ride, Hayes shot the driver in the back of his neck and 
     killed him. Hayes then took forty dollars from the driver's 
     pockets.
       Hayes was convicted of first-degree murder. Mitigating 
     evidence at the penalty phase showed that he had a 
     neglectful, abusive, and deprived upbringing, that he had 
     borderline intelligence, and that he had been consuming drugs 
     and alcohol heavily for three years. The jury recommended 
     death, and the trial court, finding that the aggravators--(1) 
     ``cold, calculated, and premeditated'' and (2) for pecuniary 
     gain and in the course of an armed robbery--clearly 
     outweighed the mitigating evidence, sentenced Hayes to death.
       The Florida Supreme Court, by a 5-2 vote, affirmed the 
     death sentence. Justice Barkett, dissenting with Kogan, would 
     have found that the mitigating evidence ``renders the death 
     sentence disproportional punishment in this case.''
       Hudson v. State, 538 So.2d 829 (Fla. 1989)--
       Two months after breaking up with his girlfriend, Hudson, 
     armed with a knife, broke into her home during the night. The 
     former girlfriend, having received threats from him, was 
     spending the night elsewhere. But her roommate was at home. 
     When she began screaming at him to leave, Hudson stabbed her 
     to death, put her body in the trunk of her car, and dumped 
     her in a drainage ditch in a tomato field. Hudson was 
     convicted and sentenced to death.
       By a 6 to 1 vote, the Florida Supreme Court affirmed the 
     death sentence. Justice Barkett, dissenting from the 
     sentence, relied on the trial court's finding that Hudson 
     ``was apparently surprised by the victim during [his] 
     burglarizing of [her] home'' in support of her view that the 
     death penalty was disproportionate to the offense.
       Analysis: Anyone who breaks into a home that he believes to 
     be occupied should expect to encounter an occupant. It is odd 
     that this would somehow become mitigating.
       King v. State, 514 So.2d 354 (Fla. 1987)--
       While an inmate at a work-release correctional facility, 
     King killed an elderly woman and robbed and burned her home. 
     He was convicted of first-degree murder and was sentenced to 
     death. The conviction and death sentence were affirmed on 
     direct appeal, and his state postconviction petition was 
     denied. On federal habeas, he obtained resentencing, but was 
     again sentenced to death.
       By a 5-2 vote, the Florida Supreme Court affirmed the 
     resentence of death. In dissent, Justice Barkett (with Kogan) 
     opined that a capital defendant must be permitted to offer at 
     the penalty phase so-called ``lingering doubt evidence''--
     evidence that the defendant might not actually be guilty of 
     the crime of which he has just been convicted beyond a 
     reasonable doubt.
       Analysis: (1) If the defendant has been found guilty beyond 
     a reasonable doubt, it follows that any evidence suggestive 
     of his innocence either has already been rejected by the jury 
     and the judge as not credible or would give rise, at most, 
     only to unreasonable or whimsical doubts. Why should evidence 
     that does not give rise to even a reasonable doubt of guilt 
     and that is not otherwise relevant in any respect be required 
     to be admitted in the sentencing phase as evidence of 
     possible innocence? (2) In Franklin v. Lynaugh, 487 U.S. 164 
     (1988), the U.S. Supreme Court rejected Justice Barkett's 
     position and made clear that it was not consistent with pre-
     existing precedent. In the words of Justice O'Connor's 
     concurring opinion, ``Our cases do not support the 
     proposition that a defendant who has been found to be guilty 
     of a capital crime beyond a reasonable doubt has a 
     constitutional right to reconsideration by the sentencing 
     body of lingering doubts about his guilt.'' 487 U.S. at 187.

                       C. Categorical exclusions

       Justice Barkett would define certain categories of 
     criminals--e.g., minors and those who are mentally retarded--
     as ineligible for the death penalty, and then would construe 
     those categories very expansively. For example:
       LeCroy v. State, 533 So.2d 750 (Fla. 1988)--
       By a vote of six to one, the court affirmed a death 
     sentence for two brutal first-degree murders by LeCroy, who 
     was 17 years and ten months when he committed the murders. 
     The court noted, among other things, that the sentencing 
     judge gave great weight to LeCroy's youth but found him 
     mentally and emotionally mature, and that Florida statutes 
     specify that a child of any age charged with a capital crime 
     ``shall be tried and handled in every respect as if he were 
     an adult.'' Construing U.S. Supreme Court precedent, it ruled 
     that there was no constitutional bar to the imposition of the 
     death penalty on those who were 17 at the time of the capital 
     offense.
       Justice Barkett, dissenting from the death sentence, stated 
     her belief that both the Eighth Amendment of the federal 
     Constitution and a state constitutional provision prohibit 
     imposition of the death penalty on one who was a ``child'' at 
     the time of the crime. ``[T]he death penalty is totally 
     inappropriate when applied to persons who, because of their 
     youth, have not fully developed the ability to judge or 
     consider the consequences of their behavior.'' 533 So.2d, at 
     758. ``I am confident that most reasonable persons would 
     agree that the death penalty cannot be imposed on children 
     below a certain age. . . . In my view, that line should be 
     drawn where the law otherwise distinguishes `minors' from 
     adults''--i.e., at 18 years. Id., at 759. ``I cannot agree, 
     as the majority implicitly holds, that one whose maturity is 
     deemed legally insufficient in other respects should be 
     considered mature enough to be executed in the electric 
     chair.'' Id.
       Analysis:
       (1) It would seem that the existing statutes permitting 
     execution of those under 18, both in Florida and in other 
     states, are a more reliable barometer than Justice Barkett's 
     own subjective sense of what ``most reasonable persons would 
     agree.''
       (2) As the majority emphasizes, the trial court found that 
     LeCroy's ability to judge the consequences of his behavior 
     was fully developed. It would seem that a State should be 
     able to choose to structure its determination on an 
     individualistic basis, rather than be required to engage in 
     the fiction that the moment a person turns 18, he acquires a 
     maturity that did not previously exist.
       (3) The relevant question is not whether someone is 
     ``mature enough to be executed'' (whatever that means); 
     rather, it is whether someone is mature enough to recognize 
     the wrong of brutally killing a human being. It is plainly 
     commonsensical, and surely constitutional, for the people of 
     a State to conclude that the degree of maturity that is 
     necessary to exercise sound judgment regarding voting or 
     marrying may be somewhat greater than the degree necessary to 
     recognize the wrong of brutally killing a human being.
       (4) In Stanford v. Kentucky, 492 U.S. 361 (1989), the U.S. 
     Supreme Court later rejected her position, as it held that 
     there was no constitutional bar to execution of 16- and 17-
     year-olds.
       In her written response to written questions submitted 
     after her hearing, Justice Barkett stated that ``there was no 
     express evidence that the Florida Legislature had considered 
     the question'' of executing minors and that her LeCroy 
     dissent ``concluded that the Legislature had not sufficiently 
     expressed its intent to execute juveniles to satisfy the 
     Eighth Amendment.''
       This response is unsatisfactory in at least two respects: 
     (1) It fails to acknowledge, much less rebut, the majority's 
     detailed demonstration that the Florida legislature had, for 
     the past 35 years, ``repeatedly reiterated the historical 
     rule that juveniles charged with capital crimes will be 
     handled in every respect as adults'' and that ``it cannot be 
     seriously argued that the legislature has not consciously 
     decided that persons seventeen years of age may be punished 
     as adults'' and be subject to the death penalty. (2) Justice 
     Barkett's written response gives the misimpression that her 
     dissent rests on the ground that the legislature was not 
     sufficiently clear. In fact, her dissent is in no way so 
     limited.
       Hall v. State, 614 So.2d 473 (Fla. 1993)--
       In 1978, Hall and another man decided to steal a car to use 
     in a robbery. They spotted a 7-month-pregnant woman in a 
     grocery store parking lot. Hall forced her into her car and 
     drove her to a secluded area, where Hall and the other man 
     raped, beat and shot her to death. Hall was convicted and 
     sentenced to death.
       By a 5-2 vote, the Florida Supreme Court affirmed Hall's 
     death sentence. The court ruled in part that the trial record 
     supported the trial judge's conclusion that the mitigators 
     alleged by Hall either had not been established or were 
     entitled to little weight.
       Justice Barkett, dissenting (with Kogan), did not agree 
     that the mitigators had not been established. Instead, she 
     would have found that Hall was mentally retarded and would 
     have held that execution of the mentally retarded is cruel 
     and unusual punishment under the Florida Constitution.
       Analysis: (1) Justice Barkett relies on provisions of the 
     Florida Constitution to reach anti-death penalty results well 
     beyond what identical provisions of the federal Constitution 
     have been construed to require. (2) Justice Barkett is often 
     more ready than her colleagues to credit the defendant's 
     mitigating evidence.

                            D. Racial quotas

       Foster v. State, No. 76,639 (Fla. Apr. 1, 1993)--
       Foster, two young women, and another man, Lanier, drove to 
     a deserted area where one of the women was to make some money 
     by having sex with Lanier. As Lanier, who was very drunk, was 
     disrobing, Foster suddenly began hitting him and then held a 
     knife to Lanier's throat and sliced his neck. Foster and the 
     women then dragged the still-breathing Lanier into the bushes 
     and covered him with branches and leaves. Foster then took a 
     knife and cut Lanier's spine. Foster and the women then split 
     the money found in Lanier's wallet.
       Foster was convicted of murder and sentenced to death in 
     1975. On resentencing, the trial court, finding three 
     aggravating circumstances, again imposed the death penalty. 
     The Florida Supreme Court, by a 4-3 vote, rejected Foster's 
     claim that his death sentence was a product of racial 
     discrimination against black victims. (The court did remand 
     for resentencing on other grounds.)
       Justice Barkett, dissenting on this point, would not accept 
     the majority's determination that Foster's statistical 
     evidence purporting to show that white-victim defendants in 
     Bay County were more likely to get the death penalty than 
     black-victim defendants failed to establish a constitutional 
     violation. (Lanier, evidently, was white; Foster, according 
     to newspaper accounts, was also white.) Justice Barkett would 
     have relied on the Florida Constitution's Equal Protection 
     Clause to reach a result rejected by the U.S. Supreme Court 
     in McCleskey v. Kemp, 481 U.S. 279 (1987). In McCleskey, the 
     Court ruled that a capital defendant claiming a violation of 
     the federal Equal Protection Clause must show the existence 
     of purposeful discrimination and a discriminatory effect on 
     him. According to Justice Barkett:
       (1) The McCleskey standard fails to address the problem of 
     ``unconscious discrimination.''
       (2) ``Statistical evidence'' of discriminatory impact in 
     capital sentencing that ``cannot be traced to blatant or 
     overt discrimination'' should establish a violation of 
     Florida's Equal Protection Clause.
       (3) This ```statistical' evidence'' should be construed 
     broadly to include not only analysis of the disposition of 
     first-degree murder cases, ``but also other information that 
     could suggest discrimination, such as the resources devoted 
     to the prosecution of cases involving white victims as 
     contrasted to those involving minority victims, and the 
     general conduct of a state attorney's office, including 
     hiring practices and the use of racial epithets and jokes.'' 
     (Emphasis in italics.)
       (4) The defendant should have the initial burden of showing 
     the strong likelihood that discrimination influenced the 
     decision to seek the death penalty. ``Such discrimination 
     conceivably could be based on the race of the victim or on 
     the race of the defendant.'' Once the initial burden has been 
     met, ``the burden then shifts to the State to show that the 
     practices in question are not racially motivated.''
       Analysis: (1) Justice Barkett's proposed standard would 
     paralyze implementation of the death penalty. (This point 
     should be kept in mind in considering her supporters' claims 
     about her death penalty record.) Under her standard, in every 
     capital case involving either a non-white defendant or a 
     white victim, the capital defendant would be able to 
     investigate the general practices of the state attorney's 
     office. A more burdensome inquiry could hardly be imagined. 
     (2) Indeed, as Justice Powell pointed out in his opinion in 
     McCleskey, there is no reason why Justice Barkett's standard 
     would be limited to cases with non-white defendants or white 
     victims. A white defendant should be able to try to show that 
     racial discrimination against whites infected the State's 
     decision. A Catholic defendant could try to show that state 
     attorneys told jokes about the priest and the rabbi, etc. A 
     female defendant (or a killer of a male victim) could try to 
     show that sexism pervades the prosecutor's office. (3) There 
     is also no reason why Justice Barkett's standard should be 
     limited to death penalty cases; her theory would apply 
     equally to robbery, rape, and all other crimes. In Justice 
     Powell's words, ``McCleskey's claim, taken to its logical 
     conclusion, throws into serious question the principles that 
     underlie our entire criminal justice system.'' McCleskey, 481 
     U.S., at 314- 315.
       At her hearing, Justice Barkett stated: ``I have not 
     suggested in this opinion or anywhere else that statistics is 
     the be-all and end-all of the inquiry. I do believe that 
     perhaps statistics may be something that could be submitted 
     to be included in an offer of proof on this question, but I 
     clearly do not believe that some questions can be resolved 
     only by use of statistical analysis.'' [157:1-6] How this 
     statement can be reconciled with her opinion--in which she 
     clearly embraces reliance on statistical evidence--is not 
     clear.

                   E. Developing procedural anomalies

       Justice Barkett has taken a number of positions that would 
     place substantial procedural roadblocks in the way of the 
     death penalty; she has taken other positions that give 
     capital defendants special advantages. In the postconviction 
     context, where the doctrine of procedural bar enables courts 
     to dispose of claims that were not timely raised or that were 
     otherwise not properly preserved, Justice Barkett has 
     frequently declined to apply the law of procedural bar as 
     uniformly as the court and has instead created ad hoc 
     exceptions. See, e.g., Bundy v. State, 538 So.2d 445 (Fla. 
     1989); Francis v. Dugger, 581 So.2d 583 (Fla. 1991); Foster 
     v. State, 518 So.2d 901 (Fla. 1987); Johnson v. State, 536 
     So.2d 1009 (Fla. 1988); Jones v. State, 533 So.2d 290 (Fla. 
     1988).
       Grossman v. State, 525 So.2d 833 (Fla. 1988)--
       Grossman, on probation following a prison term, drove with 
     a companion to a wooded area to shoot a handgun that he had 
     recently stolen from a home. When a wildlife officer came 
     upon them, she took possession of Grossman's shotgun. 
     Grossman pleaded with her not to turn him in, since he would 
     be returned to prison for violating the terms of his 
     probation. When the officer refused his plea, Grossman beat 
     her with a large flashlight. After she fired her weapon in 
     self-defense, Grossman wrestled the weapon away and shot her 
     in the back of the head, killing her. Grossman was convicted 
     and sentenced to death.
       By a 6-1 vote, the Florida Supreme Court affirmed the death 
     sentence. Justice Barkett, dissenting, would have continued 
     to adhere to a view concededly rejected by numerous Florida 
     Supreme Court decisions: namely, that the U.S. Supreme Court 
     decision in Caldwell v. Mississippi, 472 U.S. 320 (1985)--
     which held that it was error for a prosecutor to urge a 
     capital sentencing jury not to view itself as determining 
     whether the defendant would die, since the correctness of the 
     death sentence would be reviewed on appeal--applied under 
     Florida's scheme to the advisory jury as well as to the 
     sentencing judge. Justice Barkett also would not have 
     permitted written findings in support of sentencing to be 
     made three months after sentencing, where no specific oral 
     findings were made at the time that the death sentence was 
     imposed. She therefore would have required that the sentence 
     be reduced to life.
       Burr v. State, 518 So.2d 903 (Fla. 1987)--
       Burr was convicted of first-degree murder and robbery with 
     a firearm and was sentenced to death. His conviction and 
     sentence were affirmed on direct appeal. Following the 
     signing of a death warrant, he filed a motion for 
     postconviction relief, which was denied by the trial court.
       By a 6-1 vote, the Florida Supreme Court affirmed the 
     denial of relief. Justice Barkett, dissenting, would have 
     decided for Burr based on an issue that she conceded had not 
     even been raised by Burr--the consideration of collateral 
     crimes evidence during the sentencing phase.
       At her hearing, Justice Barkett claimed that ``the United 
     States Supreme Court reversed Burr on the same basis upon 
     which I dissented.'' [95:9-10] This claim is not accurate: 
     The U.S. Supreme Court GVRed--granted, vacated and remanded--
     Burr in light of its intervening decision in a case called 
     Johnson v. Mississippi, where the Court ruled that a death 
     sentence could not be based on a conviction that is no longer 
     valid. Justice Barkett's dissent is not so limited and would 
     appear to challenge the admission of any collateral crimes 
     evidence.
       Stewart v. State, 549 So.2d 171 (Fla. 1989)--
       Stewart, hitchhiking, was a passenger in a car. When the 
     driver stopped to drop him off, Stewart, struck her on the 
     head with the butt of a gun, shot her and shot and killed her 
     companion, forced them from the car, and drove away. The 
     trial judge, following the jury's recommendation, sentenced 
     Stewart to death. The trial court made detailed oral findings 
     that were dictated into the record; it failed, however, to 
     provide separate written findings in support of its sentence.
       The Florida Supreme Court, by a 5-2 vote, remanded so that 
     the trial court could provide written findings, as required 
     by an intervening decision construing state law. Justice 
     Barkett, dissenting with Kogan, would have overruled a recent 
     precedent by holding that a trial court's failure to provide 
     contemporaneous written findings required that a death 
     sentence be converted to life.
       Hamblen v. Dugger, 546 So.2d 1039 (Fla. 1989)--
       Hamblen pled guilty to first-degree murder and waived his 
     right to have a jury consider whether he should be executed. 
     At his sentencing hearing, he presented no mitigating 
     evidence and agreed with the prosecutor's recommendation of 
     death. The trial judge sentenced him to death. The sentence 
     was affirmed on direct appeal (with Justice Barkett 
     dissenting).
       The capital collateral representative then filed a habeas 
     petition on Hamblen's behalf. The Florida Supreme Court, by a 
     vote of 6-1, denied the petition. Justice Barkett, 
     dissenting, opined that a court that ``gives a defendant the 
     `right' to waive presentation of mitigating factors'' cannot 
     perform its required function of weighing the aggravating and 
     mitigating factors.
       Woods v. State, 531 So.2d 79 (Fla. 1988)--
       Justice Barkett opined that she would require a court to 
     entertain any claim made by a condemned prisoner, no matter 
     how dilatory the assertion of the claim: ``a court must 
     consider any point raised by a condemned prisoner as a reason 
     why the death penalty should not be imposed.''
       Analysis: One of the problems in state administration of 
     the death penalty has been the deliberate 11th-hour filing of 
     claims by death row inmates whose sentences have been validly 
     imposed and upheld both on direct and collateral appeal. At 
     some reasonable point, a State must be permitted to prevent 
     abuse of its criminal justice system. Otherwise, a death row 
     inmate could delay his execution forever simply by filing 
     another claim. Justice Barkett's dissent does not seem at all 
     attentive to the legitimate interests of the State.

                         F. Providing no reason

       In some 50 or so cases, Justice Barkett has provided no 
     explanation--or at times only a conclusory statement--when 
     she has refused simply to join the opinion of the court. In a 
     number of these cases, she actually voted to grant relief. 
     For example:
       White v. State, 559 So.2d 1097 (Fla. 1990)--
       White was convicted of robbing a small grocery store and 
     shooting to death a customer. His conviction and death 
     sentence were affirmed on appeal. In a petition for 
     postconviction relief, White claimed, among other things, 
     that his counsel had been ineffective. The Florida Supreme 
     Court, by a vote of 5 to 2, affirmed the denial of his 
     petition; in particular, the court addressed in detail, and 
     found meritless, White's claim of ineffective assistance of 
     counsel.
       Justice Barkett's entire dissent reads as follows: ``I 
     cannot concur in the majority's conclusion that appellant 
     received a fair trial with effective assistance of counsel.''
       When asked at her hearing why she did not provide any 
     further explanation for overturning a sentence recommended by 
     the jury, imposed by the trial judge, affirmed on direct 
     appeal, and upheld by the trial judge and the majority of her 
     colleagues in postconviction proceedings, Justice Barkett 
     stated: ``[O]ur court is an extremely busy court. . . . I 
     would have liked to have had, I am sure, the opportunity to 
     have expanded here. But time constraints sometimes preclude 
     you from amplifying any further than that.'' [87:8-17] This 
     response does not adequately explain why Justice Barkett 
     failed even to identify the primary reasons that led her to 
     dissent.
       Engle v. Florida, 510 So.2d 881 (Fla. 1987)--
       Engle and another man robbed $67 from a convenience store, 
     took the female cashier from the store, and strangled and 
     stabbed her to death. A four-inch laceration, likely caused 
     by a fist, was found in the interior of the victim's vagina. 
     The jury recommended life, but the trial judge, finding four 
     aggravators and no mitigators, sentenced Engle to death.
       By a vote of 6-1, the Florida Supreme Court ruled that 
     there was not a reasonable basis for the jury's life 
     recommendation and affirmed the death sentence. Justice 
     Barkett, in a two-sentence dissent, stated, without any 
     further explanation, her belief that ``the record adequately 
     supports the jury's recommendation of life imprisonment.''
       See also Kennedy v. Wainwright, 483 So.2d 424 (Fla. 1986); 
     Thomas v. Wainwright, 486 So.2d 574 (Fla. 1986); Thomas v. 
     Wainwright, 486 So.2d 577 (Fla. 1986); Funchess v. State, 487 
     So.2d 295 (Fla. 1986); Spaziano v. State, 570 So.2d 289 (Fla. 
     1990); Swafford v. Dugger, 569 So.2d 1264 (Fla. 1990); Turner 
     v. State, 530 So.2d 45 (Fla. 1987).

G. Other noteworthy cases Torres-Arboledo v. State, 524 So.2d 403 (Fla. 
                                1988)--

       Torres-Arboledo, an illegal alien from Colombia, rounded up 
     two other men and went to a car body shop, where they 
     attempted to take the owner's gold chain. When the owner 
     resisted, Torres-Arboledo shot him to death. The jury 
     recommended a life sentence, but the trial judge, finding two 
     aggravators and no mitigators, overrode it and imposed death.
       The Florida Supreme Court, by a 6-1 vote, affirmed the 
     death sentence. Justice Barkett, in a three-sentence dissent, 
     opined that the standard for overriding a jury life 
     recommendation had not been met: ``In light of the totality 
     of the circumstances presented, it simply cannot be said that 
     no reasonable jury could have recommended life.''
       In a number of other cases, Justice Barkett has been far 
     more ready than her colleagues to find that a trial judge's 
     override of a jury's life recommendation was not warranted. 
     See, e.g., Routly v. Wainwright, 590 So.2d 397 (Fla. 1991); 
     Johnson v. State, 536 So.2d 1009 (Fla. 1988).
       Swafford v. State, 533 So.2d 270 (Fla. 1988)
       Facts: The body of a female gas station attendant was found 
     in a wooded area by a dirt road some miles from where she 
     worked. She had been sexually battered and shot nine times, 
     twice in the head. Swafford was convicted and sentenced to 
     death. At his trial, evidence included testimony regarding an 
     incident that took place two months after the murder: A 
     witness, Johnson, testified that Swafford suggested that they 
     ``go get some women'' and proceeded to say that ``we'll do 
     anything we want to her'' and then ``I'll shoot her in the 
     head twice.'' In response to Johnson's question whether that 
     wouldn't bother him, Swafford said that ``it does for a 
     while, you know, you just get used to it.'' Swafford then 
     proceeded to target a victim and draw his gun, but Johnson 
     ended the enterprise.
       By a vote of 5-2, the Florida Supreme Court affirmed the 
     death sentence. The majority held that Johnson's ``other 
     acts'' evidence was admissible under the state counterpart to 
     Rule 404(2) of the Federal Rules of Evidence as evidence of 
     the meaning of Swafford's statement that ``you just get used 
     to it,'' and that this statement, in context, was relevant to 
     establishing his crime two months before.
       Justice Barkett, dissenting, asserted that the ``only 
     relevance of this testimony was to establish the criminal 
     propensity and character of Swafford'' and that it should 
     therefore have been excluded under Rule 404(2).
       Analysis: The majority's analysis is sound. While one might 
     question how probative Swafford's statement was, Justice 
     Barkett is wrong when she says its ``only relevance'' is to 
     propensity and character.


    III. CLAIMS REGARDING JUSTICE BARKETT'S PRO-DEATH PENALTY VOTES

       Justice Barkett's supporters have routinely claimed that 
     she has voted to enforce the death penalty in more than 200 
     cases. The White House has made available a list of 275 
     supposed such cases. Here is a statement made by Senator 
     Hatch at Justice Barkett's hearing in response to these 
     statistical claims:
       ``The White House and other supporters of Justice Barkett's 
     nomination have made statistical claims regarding her death 
     penalty record in an effort to rebut charges that she is soft 
     on the death penalty. In support of these statistical claims, 
     the White House has produced a lengthy table of her death 
     penalty rulings. I would like to respond to these claims.
       ``Let me say at the outset that I believe that judges 
     should be judged by the quality of their legal reasoning and 
     by their fidelity to the law. A careful examination of 
     particular opinions is the best measure of these qualities. 
     It is precisely such an examination that I have conducted and 
     hope to continue at this hearing. By contrast, because the 
     craft of judging lies foremost in reasoning and not in 
     results, broad statistical compilations of results often 
     obscure far more than they clarify.
       ``Unfortunately, the White House's statistics suffer from 
     more than the usual deficiencies. In the first place, the 
     table of death penalty cases contains pervasive 
     doublecounting. In particular, where (as routinely happens) 
     the Florida supreme court addresses both a Rule 3.850 
     postconviction petition and a habeas petition in the same 
     case, the White House counts this case as two cases. This 
     doublecounting has the predictable effect of padding the list 
     of cases in which the White House says that Justice Barkett 
     has voted to enforce the death penalty. Even more remarkably, 
     it has the perverse effect of including in this list of 
     supposed votes to enforce the death penalty numerous cases in 
     which Justice Barkett has in fact voted to grant relief to 
     the petitioning convicted murderer.
       ``Second, the White House's list of cases in which Justice 
     Barkett ``has voted with the majority'' is not limited to 
     those cases in which she has been part of the majority. It 
     includes, for example, a substantial number of cases in which 
     she has refused to join the majority and has instead either 
     dissented in part or relied on grounds significantly more 
     adverse to the death penalty. It also includes a very large 
     number of cases in which, without offering any explanation, 
     she has merely concurred in the result.
       ``Thus, for example, a case such as Foster v. State--in 
     which Justice Barkett, in partial dissent, takes a position 
     that would virtually paralyze implementation of the death 
     penalty--is listed by the White House as a case in which 
     Justice Barkett and the majority are in agreement. [Case 91 
     on White House list] Other examples abound. For example, 
     Melendez v. State [498 So.2d 1258 (Fla. 1986)]--# 576 on the 
     White House list--is identified as a case in which the 
     majority and Justice Barkett were in agreement even though 
     Justice Barkett, writing separately in that case, opined that 
     she ``believe[d] that the evidence does not rise to the level 
     of certainty that should support imposition of the death 
     penalty.'' Likewise, if one starts running through the list 
     chronologically, in three of the very first cases [Kennedy v. 
     Wainwright, 483 So.2d 424 (Fla. 1986) (#625 on list), Adams 
     v. Wainwright, 484 So.2d 1211 (Fla. 1986) (#624 on list), and 
     Thomas v. Wainwright, 486 So.2d 574 (Fla. 1986) (#621 on 
     list)], Justice Barkett voted to stay the petitioner's 
     execution and the majority did not, but the White House fails 
     to identify this disagreement.
       ``A third basic flaw in the White House's statistical 
     analysis is that the White House fails to compile, much less 
     analyze, case histories of death-sentenced convicts. It is 
     not at all unusual for a death-sentenced murderer to make 
     numerous passes through the court system. This point is shown 
     by the fact that the set of 275 occasions on which the White 
     House says that Justice Barkett has voted to enforce the 
     death penalty comprises well under 200 separate convicted 
     murderers, many or most of whom will make yet more passes at 
     escaping their sentence. In this regard, it bears mention 
     that of these fewer than 200 murderers, Justice Barkett would 
     have granted relief, even beyond what her court had elsewhere 
     granted or what her positions in yet other cases might 
     dictate, to some one-third of them somewhere along the line.
       ``The White House also makes certain statistical claims 
     regarding Justice Barkett's death penalty cases and the U.S. 
     Supreme Court. It states, for example, that ``on eight 
     occasions since 1987, Justice Barkett has voted to impose the 
     death penalty in cases where a majority of the U.S. Supreme 
     Court has voted to vacate that punishment.'' But the White 
     House fails to make clear a number of relevant matters:
       ```In none of these cases did the U.S. Supreme Court rule 
     that the death sentence could not be imposed or even that 
     resentencing was necessary.
       ```Indeed, only one of these eight cases was even argued 
     before the Court. In the other seven cases, the Supreme Court 
     used the procedural device known as a GVR --grant, vacate, 
     and remand--to enable the state supreme court to consider the 
     possible impact of an intervening U.S. Supreme Court 
     decision. The Supreme Court liberally uses this GVR device, 
     especially in death cases. A GVR does not necessarily reflect 
     disagreement with the state supreme court's ruling; rather, 
     it simply gives the state supreme court the opportunity to 
     consider the possible application of the intervening U.S. 
     Supreme Court decision.
       ```In the one case that was decided on the merits, the 
     Supreme Court remanded so that the Florida supreme court 
     could make the basis for its ruling more clear. In seven of 
     these eight cases, the death penalty was imposed on remand 
     from the Supreme Court. In short, these cases provide no 
     meaningful basis for a comparison of how Justice Barkett 
     stands in relation to the Supreme Court on the death 
     penalty.'
       ``The White House also asserts that `in four cases in which 
     Justice Barkett dissented from a death sentence and that case 
     was reviewed by the U.S. Supreme Court, the Court agreed with 
     Justice Barkett, and not the Florida Supreme Court majority.' 
     In fact, however, the Supreme Court did not agree with the 
     legal position that Justice Barkett took in any of the four 
     cases. Instead, it relied on other grounds in summarily 
     vacating the death sentence in one of the cases and issuing 
     GVRs in light of intervening precedent in the other three.
       ``For these same reasons, the White House's claim regarding 
     the `nine instances in which the U.S. Supreme Court has 
     reached a conclusion different from Rosemary Barkett's in a 
     capital case' misses the mark. I must also note that the 
     White House fails to consider those cases from other 
     jurisdictions in which the U.S. Supreme Court has rejected 
     the very positions taken by Justice Barkett in other cases.
       ``The White House also fails to observe a striking fact 
     that the statistics do show. Even if one accepts the White 
     House's loaded numbers, these numbers show that there have 
     been more than one hundred occasions on which Justice Barkett 
     has dissented from the Florida Supreme Court's decision to 
     enforce the death penalty. By contrast, there has not been 
     one occasion--not one single occasion--on which Justice 
     Barkett has been in dissent from a majority decision to grant 
     relief to a convicted capital murderer. This drastic 
     disparity makes all the more telling the White House's 
     refusal to compile--or at least to disclose--data on any 
     cases in which even a single justice has taken a position 
     that is more favorable to the convicted murderer than Justice 
     Barkett's.
       ``I emphasize again that I believe that a careful reading 
     of a judge's cases is the best means of examining that 
     judge's record.''

            Justice Barkett's Constitutional Decisionmaking

       Florida chief justice Rosemary Barkett, who has been 
     nominated for a seat on the Eleventh Circuit Court of 
     Appeals, has a record of constitutional decisionmaking that 
     merits careful scrutiny. This memorandum will discuss some 
     opinions of hers that raise serious concerns. In particular, 
     it will focus on her constitutional decisionmaking in such 
     areas as equal protection, substantive due process, the First 
     Amendment, obscenity, and quotas.
       As one would expect with any judge who has decided a large 
     number of cases, Justice Barkett has, of course, written a 
     number of opinions that are unobjectionable or soundly 
     reasoned. But the broader question is whether her judicial 
     record reflects a strong commitment to apply the Constitution 
     and laws as written, or whether it instead reflects an 
     inclination to impose her own policy outlook in the guise of 
     judging.\1\
---------------------------------------------------------------------------
     \1\ The case summaries in this memorandum are not intended to 
     discourage the reader from reviewing the opinions themselves. 
     Indeed, we encourage such review. In addition, the transcript 
     of Justice Barkett's hearing is available for review in the 
     minority office of the Senate Judiciary Committee.
---------------------------------------------------------------------------


       i. rational-basis review under the equal protection clause

       The U.S. Supreme Court's equal protection jurisprudence is 
     well-settled: ``this Court's cases are clear that, unless a 
     classification warrants some form of heightened review 
     because it jeopardizes exercise of a fundamental right or 
     categorizes on the basis of an inherently suspect 
     characteristic, the Equal Protection Clause requires only 
     that the classification rationally further a legitimate state 
     interest.'' Nordlinger v. Hahn, 112 S. Ct. 2326, 2331-2332 
     (1992).
       How this rational-basis test is to be applied is also well-
     settled. As Justice Blackmun reiterated in Nordlinger (for an 
     8-Justice majority), ``the Equal Protection Clause is 
     satisfied so long as there is a plausible policy reason for 
     the classification, the legislative facts on which the 
     classification is apparently based rationally may have been 
     considered to be true by the government decisionmaker, and 
     the relationship of the classification to its goal is not so 
     attenuated as to render the distinction arbitrary or 
     irrational.'' Nordlinger v. Hahn, 112 S. Ct. 2326, 2332 
     (1992) (citations omitted).
       The Supreme Court, citing cases going back to 1970, 
     reiterated these basic principles earlier this year in 
     another 8-Justice opinion (written by Justice Thomas):
       ``[E]qual protection is not a license for courts to judge 
     the wisdom, fairness, or logic of legislative choices. In 
     areas of social and economic policy, a statutory 
     classification that neither proceeds along suspect lines 
     nor infringes fundamental constitutional rights must be 
     upheld against equal protection challenge if there is a 
     reasonably conceivable state of facts that could provide a 
     rational basis for the classification. . . . This standard 
     of review is a paradigm of judicial restraint. . . . On 
     rational basis-review, a classification in a statute . . . 
     comes to us bearing a strong presumption of the 
     legislative classification have the burden `to negative 
     every conceivable basis which might support it.'''

     FCC v. Beach Communications, 113 S. Ct. 2096, 2101-2102 
     (1993) (emphasis in italic) (case citations omitted).
       Examination of Justice Barkett's cases calls into serious 
     question whether she has been faithful to this ``paradigm of 
     judicial restraint.'' In the case of University of Miami v. 
     Echarte, 618 So. 2d 189 (Fla. 1993), the Florida Supreme 
     Court ruled that a statutory monetary cap on noneconomic 
     damages in medical malpractice cases did not violate Equal 
     Protection. The court cited at length the legislature's 
     concern over the ``financial crisis in the medical liability 
     insurance industry''; its concern that providers of medical 
     care would ``be unable to purchase liability insurance, and 
     many injured persons [would] therefore be unable to recover 
     damages''; its recognition that the size and increasing 
     frequency of very large claims was a cause of these problems; 
     and its concern that damages for noneconomic losses were 
     being awarded arbitrarily and irrationally.
       In dissent, Justice Barkett (among other grounds) her view 
     that the statutory caps ``violate[ ] . . . the equal 
     protection clauses of the Florida and United States 
     Constitutions.'' (Emphasis in italic.) In her view, the caps 
     could not survive even minimal rational-basis scrutiny. Her 
     application of the rational basis test appears to differ 
     fundamentally from the settled test set forth by the U.S. 
     Supreme Court. Justice Barkett does not cite any federal 
     precedent. Instead, she makes a startling assertion: ``I fail 
     to see how singling out the most seriously injured medical 
     malpractice victims for less than full recovery bears any 
     rational relationship to the Legislature's stated goal of 
     alleviating the financial crisis in the medical liability 
     insurance industry.'' In fact, the rational relationship 
     between the means and the goal appears self-evident and was 
     clearly spelled out by the legislature. Thus, it is difficult 
     to avoid the conclusion that instead of giving the 
     legislation the ``strong presumption of validity'' to which 
     it is entitled, Justice Barkett is substituting her own 
     policy preferences in place of those of the legislature 
     through the purported application of rational-basis review.
       The point here is not the merits, or lack of merits, of 
     caps on noneconomic damages as a matter of policy. The point, 
     rather, is that under clear Supreme Court precedent issues 
     like this are left broadly to the legislatures. It is a cause 
     of great concern that Justice Barkett, first, would rely on 
     the federal Equal Protection Clause (since state law grounds, 
     under her view, sufficed to reach the same result), and, 
     second, would fail to follow clear and longstanding Supreme 
     Court precedent in applying that clause. More generally, one 
     must be very concerned that a judge who would so casually 
     invoke the federal Equal Protection Clause to invalidate 
     legislative action in this area is very ready to continue to 
     misuse the federal Equal Protection Clause--a very powerful 
     tool if so misused--to impose her policy preferences instead 
     of applying the law.
       This concern has very broad ramifications. For example, 
     Congress might well enact damage caps as part of product 
     liability reform or as part of medical liability reform under 
     a health care bill. Because the U.S. Supreme Court has held 
     that the equal protection principle applies to the federal 
     government under the Fifth Amendment's due process clause, 
     the logic of Justice Barkett's position would seem almost 
     certainly to lead to these caps being struck down.
       At her hearing Justice Barkett said that Echarte was 
     ``primarily'' a case implicating the state constitutional 
     right of access to the courts. [47:9-48:3] ``I grant you that 
     I used the term `Federal Constitution,' but . . . the 
     analysis is totally using Florida cases under a Florida 
     system.'' [48:12-15] She ultimately conceded that she should 
     not have invoked the federal equal protection clause: ``The 
     only reaching out was including the phrase `Federal 
     Constitution,' I should not have done that.'' [50:12-14]
       Justice Barkett's response heightens the concern that she 
     invokes the federal Constitution in a cavalier and clearly 
     erroneous manner. The fact that she cited only Florida cases 
     emphasizes, rather than assuages, this concern.
       Another Equal Protection case that raises similar concerns 
     is Shriners Hospitals v. Zrillic, 563 So.2d 64 (Fla. 1990). 
     There, Justice Barkett wrote the opinion for the court 
     striking down, on numerous bases, a Florida statute that 
     permitted a direct heir to cancel a gift to charity made in a 
     will when that will was executed less than six months before 
     the testator's death. The purpose of the statute was to guard 
     against undue influence on charitable gift givers. One of the 
     bases on which she struck down the statute was the federal 
     Equal Protection Clause.
       Again, the concern here is not with the wisdom, or lack of 
     wisdom, of the statute, but rather with the reasoning by 
     which she used the federal Equal Protection clause to 
     invalidate it. In that case, she stated,
       ``Equal protection analysis requires that classifications 
     be neither too narrow nor too broad to achieve the desired 
     end. Such underinclusive or overinclusive classifications 
     fail to meet even the minimal standards of the rational basis 
     test.''
       Her opinion proceeds to hold that the statute is 
     underinclusive because it protects against only one type of 
     undue influence exerted on testators (that exerted by 
     charities), and that it is overinclusive because it would 
     render voidable many intentional bequests not tainted by 
     undue influence. Her opinion further states that the six-
     month period set forth in the statute is irrational; in her 
     words; ``[t]here is no rational distinction to automatically 
     void a devise upon request when the testator survives the 
     execution of a will by five months and twenty-eight days, but 
     not when the testator survives a few days longer.''
       Justice Barkett's opinion cites no federal authority for 
     the proposition that the rational basis test for the federal 
     equal protection clause forbids both underinclusive and 
     overinclusive classifications. Nor could she, for this 
     proposition appears plainly incorrect: the U.S. Supreme Court 
     has long held that a classification does not violate Equal 
     Protection simply because it ``is to some extent 
     underinclusive and overinclusive.'' Vince v. Bradley, 440 
     U.S. 93, 108 (1979). As Justice Douglas stated in an opinion 
     for the Court more than 40 years ago, ``It is no requirement 
     of equal protection that all evils of the same genus be 
     eradicated or none at all.'' Railway Express Agency v. New 
     York, 336 U.S. 106, 110 (1949). The Court restated this basic 
     principle just last year: ``[T]he legislature must be allowed 
     leeway to approach a perceived problem incrementally. . . . 
     `[It] may take one step at a time, addressing itself to the 
     phase of the problem which seems most acute to the 
     legislative mind. The legislature may select one phase of one 
     field and apply a remedy there, neglecting the others.''' FCC 
     v. Beach Communications, 113 S. Ct., at 2102 (quoting 
     Williamson v. Less Optical, 348 U.S. 483 (1955)).
       Justice Barkett's ruling that the six-month period is 
     irrational simply because it produces different results when 
     the testator survives 5 months and 28 days versus 6 months 
     and 1 day is also deeply troubling. A similar objection could 
     be voiced against every time limit in the law. But in such 
     matters the legislature ``ha[s] to draw the line somewhere,'' 
     Beach Communications, 113 S. Ct., at 2102, and when it does 
     so, the ``restraints on judicial review have added force, 
     ``id.--restraints ignored by Justice Barkett in her opinion 
     in this case.
       Again, this case goes very far towards 
     transforming rational-basis scrutiny into strict scrutiny. 
     Indeed, if applied consistently, there are few laws that 
     could survive the test that Justice Barkett sets forth. 
     (For example, a law that terminates welfare benefits after 
     two years would be clearly susceptible to invalidation 
     under Justice Barkett's equal protection analysis.) Of 
     equal concern is the prospect that the test would not be 
     applied consistently, but would be used arbitrarily and 
     selectively to strike down particular laws that one 
     considers unsound.
       As with Echarte, Justice Barkett asserted that ``the thrust 
     of that [Zrillic] opinion again was grounded in the Florida 
     Constitution.'' [53:19-20] ``[E]qual protection . . . is 
     really not at all the focus which concerned me in Zrillic.'' 
     [123:3-6] [Even though she specifically invoked the federal 
     equal protection clause, she said that ``when I am thinking 
     equal protection, generally I am thinking in terms of the 
     prior case law of my own court in my own State.'' [53:25-
     54:2] Why, then, did she invoke the federal equal protection 
     clause? Again, her response reflects an alarmingly cavalier 
     attitude towards constitutional interpretation.
       Indeed, her use of the federal Equal Protection Clause in 
     Echarte and Zrillic is all the more striking in light of her 
     partial dissent in Foster v. State (discussed more fully 
     below and in other memoranda). There, Justice Barkett 
     recognized that the U.S. Supreme Court decision in McCleskey 
     v. Kemp foreclosed her from using the federal Equal 
     Protection Clause as the basis for a statistical attack on 
     the death penalty, so she instead relied solely on the 
     Florida constitution's counterpart.
       It must be noted that the fact that Justice Barkett had 
     available sufficient state law grounds makes all the more 
     troubling her invocation of federal equal protection: not 
     only is she making bad federal constitutional law (which 
     activist judges in other courts might later rely on), but she 
     is also, in effect, immunizing her ruling from U.S. Supreme 
     Court review (since the existence of sufficient state law 
     grounds deprives that Court of Jurisdiction).
       The danger of unprincipled, result-oriented decisionmaking 
     that results from this misstatement of Equal Protection 
     principles can perhaps be illustrated by comparing Justice 
     Barkett's opinion in this Zrillic case to her dissent in 
     LeCroy v. State, 533 So.2d 750 (Fla. 1988). In LeCroy, the 
     six other Justices voted to affirm the death sentence for a 
     murderer who was 17 years and 10 months old at the time that 
     he committed two brutal first-degree murders. In her lone 
     dissent, Justice Barkett took the position that the Eighth 
     Amendment prohibits the execution of a person who was under 
     18 at the time of his offense. In short, she took the view 
     that the Constitution imposed a bright-line age minimum of 18 
     for offenses that can result in the death penalty. (The U.S. 
     Supreme Court subsequently rejected the position that she 
     took.)
       For present purposes, it is revealing to apply the 
     methodology of her Shriners opinion to the position that she 
     took in LeCroy. Applying that Shriners methodology, one would 
     say that a bright-line age minimum of 18 is both 
     underinclusive and overinclusive. It is underinclusive 
     because it fails to protect from capital punishment those 
     persons over 18 who (in the language of her LeCroy dissent) 
     ``have not fully developed the ability to judge or consider 
     the consequence of their behavior.'' It is overinclusive 
     because it does protect those under 18 who have in fact fully 
     developed their deliberative faculties. Moreover, her 
     Shriners methodology would appear to dictate the conclusion 
     that the 18-year bright line is simply irrational, since it 
     would exempt from the death penalty a heinous murderer who 
     was 17 years, 11 months, and 28 days at the time of his 
     offense, but would not exempt someone who was a few days 
     older. In short, her Shriners methodology leads to the 
     conclusion that what she thought in LeCroy to be 
     constitutionally mandated under the Eighth Amendment is 
     instead constitutionally impermissible under the Equal 
     Protection clause.
       In sum, Justice Barkett's serious misapplication of 
     rational-basis review under the Equal Protection Clause 
     allows a judge to substitute his or her own policy 
     preferences for the legislature's legitimate enactments.


                      ii. substantive due process

       The manner in which Justice Barkett has invoked 
     ``substantive due process''--even where no fundamental right 
     is at stake and rational-basis review is therefore in order--
     also raises serious concerns. In State v. Saiez, 489 So.2d 
     1125 (Fla. 1986), for example, she wrote an opinion holding 
     that a state law criminalizing the possession of embossing 
     machines capable of counterfeiting credit cards ``violate[d] 
     substantive due process under the fourteenth amendment to the 
     United States Constitution'' (as well as under Florida's 
     constitution). Specifically, she stated that the law was 
     ``not reasonably related to achieving [the] legitimate 
     legislative purpose'' of curtailing credit card fraud. In her 
     words, ``It is unreasonable to criminalize the mere 
     possession of embossing machines when such a prohibition 
     clearly interferes with the legitimate personal and property 
     rights of a number of individuals who use embossing machines 
     in their businesses and for other non-criminal activities.'' 
     Justice Barkett cited no federal authority in support of this 
     proposition.
       The principle set forth in Saiez, if taken seriously, 
     would have far-reaching consequences. A broad range of 
     criminally proscribed items also have legitimate uses. 
     Switchblades can be used to slice apples. Marijuana can be 
     prescribed as medicine. Drug paraphernalia can be used for 
     tobacco. Explosive devices can be used to build tunnels. 
     It is extraordinary to conclude that ``substantive due 
     process'' or any other principle of law disables society 
     from determining that the harmful effects of some or all 
     of these so outweigh the beneficial effects that 
     possession should be criminalized. Again, the real danger 
     is that this overbroad and unsound principle can be 
     applied selectively in an unprincipled manner.
       Justice Barkett acknowledged that she had relied on the 
     federal due process clause, but again thought such reliance 
     mitigated by the fact that she had discussed only cases 
     construing the state constitutional counterpart: ``if you go 
     on to look at the language that is used from other cases, 
     they are all Florida cases which have utilized the same 
     phrase, but interpreted it in a different way.'' [126:12-15] 
     When asked why she didn't apply just the State due process 
     clause, she responded: ``I think in essence I did, Senator, 
     and all I can--I mean, I can certainly accept that in a body 
     of law there are going to be occasions when you are going to 
     be careless.'' [129:6-9]


                 iii. loitering and the first amendment

       In her plurality opinion (over a vigorous 3-justice 
     dissent) in Wyche v. State, 619 S.2d 231 (Fla. 1993), Justice 
     Barkett struck down as facially unconstitutional an ordinance 
     that prohibited loitering for the purpose of prostitution. In 
     companion cases decided the same day as Wyche--E.L. v. State, 
     619 S.2d 252 (Fla. 1993), and Holliday v. City of Tampa, 619 
     So.2d 244 (Fla. 1993)--she likewise struck down as facially 
     unconstitutional ordinances prohibiting loitering for the 
     purpose of engaging in drug-related activity.
       Her first holding in Wyche was that the ordinance did not 
     require proof of intent to engage in unlawful acts of 
     prostitution. This holding is puzzling. The language of the 
     ordinance--criminalizing loitering ``in a manner and under 
     circumstances manifesting the purpose of inducing, enticing, 
     soliciting, or procuring another to commit an act of 
     prostitution''--appears plainly amenable to a reading that 
     the purpose that must be manifested actually exist. In 
     addition, the ordinance specifically provided, ``No arrest 
     shall be made for a violation of this subsection unless the 
     arresting officer first affords such person the opportunity 
     to explain this conduct, and no one shall be convicted of 
     violating this subsection if it appears at trial that the 
     explanation give was true and disclosed a lawful purpose.'' 
     Especially in the criminal law, where such mens rea 
     requirements are routinely implied, it seems quite a stretch 
     to construe the ordinance otherwise.
       Justice Barkett offered the view that to construe the 
     ordinance to have a specific intent requirement would be to 
     ``legislate'' from the bench. But it seems that it would have 
     been more consistent with the judicial role to invoke a tenet 
     that is basic to our separation-of-powers system and that was 
     clearly recognized in Florida case law: namely, that courts 
     ``have a duty to avoid a holding of unconstitutionality if a 
     fair construction of the legislation will so allow.'' State 
     v. Ecker, 311 So.2d 104, 109 (Fla. 1975).
       Justice Barkett's second holding in Wyche was that, even if 
     the ordinance were construed to require specific intent to 
     engage in unlawful acts of prostitution, it ``still would be 
     subject to unconstitutional application'' and therefore would 
     chill protected speech in violation of the First Amendment. 
     But virtually every law could hypothetically be applied in an 
     unconstitutional manner that could chill First Amendment 
     speech. Under First Amendment doctrine, a person challenging 
     a law as facially overbroad must show that it would reach a 
     substantial amount of constitutionally protected activity. It 
     is difficult to see how the ordinance, if construed to 
     require specific intent, would reach any constitutionally 
     protected activity, much less a substantial amount.
       The one federal case that Justice Barkett cites in support 
     of her holding, Board of Airport Commissioners v. Jews for 
     Jesus, Inc., 482 U.S. 569 (1987), is plainly inapposite. The 
     Supreme Court in Jews for Jesus simply stated that the 
     regulation in that case--which banned all First Amendment 
     activities at an airport--could not be permitted to be 
     remedied by case-by-case adjudication. To compare the 
     absolutist ban on First Amendment speech in that case to the 
     hypothetical and purely incidental effect on speech arguably 
     resulting from the ordinance in Wyche is strained in the 
     extreme.
       Another serious problem with Justice Barkett's opinion in 
     Wyche is that it is at serious odds with--indeed, appears 
     irreconcilable with--the Florida Supreme Court's 1975 ruling 
     in State v. Ecker, 311 So.2d 104 (Fla. 1975), which held that 
     a general anti-loitering statute was constitutional. Indeed, 
     Wyche appears to overrule Ecker without even citing it or 
     otherwise acknowledging it. This is not a proper way to deal 
     with precedent.
       Asked about Wyche, Justice Barkett repeatedly claimed that 
     all members of her court agreed that the statute was 
     defective but that the dissent was ready to remedy it. 
     [186:10-11, 186:25-187:1, 187:8-9] In fact, however, the 
     dissent stated that the statute was facially constitutional 
     (i.e., was not defective).
       The net effect of Wyche, E.L., and Holliday is to hamper 
     severely the ability of communities to combat the scourges of 
     prostitution and drugs.


                             iv. obscenity

       In Stall v. State [570 So.2d 257 (Fla. 1990)], the Florida 
     Supreme Court ruled--as it had several times before--that 
     Florida's laws against obscenity were constitutional. In a 
     brief 4-paragraph dissent, Justice Barkett took the position 
     that all criminal obscenity laws violate due process. (She 
     also joined another dissent that held that obscenity laws 
     violate the state right of privacy.) In her words:
       ``A basic legal problem with the criminalization of 
     obscenity is that it cannot be defined. . . . Thus, this 
     crime, unlike all other crimes, depends, not on an objective 
     definition obvious to all, but on the subjective definition, 
     first, of those who happen to be enforcing the law at the 
     time, and, second, of the particular jury or judges reviewing 
     the case. Such a procedure runs counter to every principle of 
     notice and due process in our society.''
       Arguably, Justice Barkett might intend that her due process 
     holding rest only on the state constitution, though she 
     invokes ``every principle of notice and due process in our 
     society.'' In any event, she does not even cite, much less 
     discuss, U.S. Supreme Court precedent, such as Miller v. 
     California, 413 U.S. 15 (1973), that contradicts her 
     position. Miller held that material that, judged by 
     contemporary community standards, appeals to the prurient 
     interest, that depicts or describes, in a patently offensive 
     way, specifically defined sexual conduct, and that lacks 
     serious literary, artistic, political, or scientific value 
     can be outlawed as obscene.
       Indeed, it appears that Justice Barkett misreads or 
     mischaracterizes the law that she would strike down. The 
     Florida law incorporated Miller's focus on contemporary 
     community standards as the benchmark of whether material is 
     obscene. Thus, the role of jurors would not be to make their 
     own ``subjective definition'' of what is obscene (as Justice 
     Barkett suggests), but rather to discern and apply the 
     existing community standards.
       Further, the premise of Justice Barkett's position--namely, 
     that obscenity laws are somehow unique--is dubious. There are 
     any number of criminal laws whose definition or application 
     is not any more ``objective'' than obscenity laws. Take, for 
     example, criminal negligence or child neglect. Indeed, the 
     difference between justifiable self-defense and unjustified 
     homicide can equally be said to turn ``on the subjective 
     definition, first, of those who happen to be enforcing the 
     law at the time, and, second, of the particular jury or 
     judges reviewing the case.'' These features are an inherent 
     part of our criminal justice system. So it seems that her 
     basic premise cannot be maintained and that no special 
     solicitude for obscenity is warranted.
       At her hearing, Justice Barkett stated that the statute in 
     Stall ``had language in it which, in my judgment, was very 
     ambiguous.'' [105:8-10] But since the language of the Stall 
     statute was the Miller standard, this suggests that Justice 
     Barkett is not content with the Miller standard. Given 
     Justice Barkett's treatment of other Supreme Court precedents 
     mentioned in this and other memoranda, there is reason to 
     worry that her apparent disagreement with this standard would 
     lead her to apply it too narrowly.
       Justice Barkett also claimed at length that her opinion in 
     Stall needs to be read together with her vote in Schmitt v. 
     State, 590 So.2d 404 (Fla. 1991), where she joined the per 
     curiam opinion upholding a conviction under Florida's child 
     pornography statute. Justice Barkett repeatedly claimed that 
     the two cases involved ``the very same statute'' [106:25]: 
     ``in both those cases, the same statute was being decided, 
     the same statute was being considered''. [106:16-17] In fact, 
     however, Stall involved the definition of obscenity under 
     Fla. Stat. 847.001, whereas Schmitt involved the definition 
     of child pornography under Fla. Stat. 827.071. Justice 
     Barkett's apparent claim that the court's decision in Schmitt 
     somehow vindicated her position in Stall [see 107:15-22] 
     cannot be sustained. (She may also be claiming that her 
     dissent in Stall was confined to her disagreement with the 
     definition of ``sexual conduct'' in subsection 847.001(11), 
     which is identical to the definition of ``sexual conduct'' in 
     the child pornography law. But: (a) nothing in her dissent 
     remotely supports such a limited reading, and (b) the 
     separate requirement in the obscenity law of ``appeal to the 
     prurient interest''--a requirement not present in the child 
     pornography statute--eliminates any overbreadth and makes 
     such a claim untenable.)


                               v. quotas

       Justice Barkett's views on quotas are of serious concern. 
     According to newspaper reports, Justice Barkett was a member 
     of the Florida Commission on the Status of Women, which 
     issued a report in February 1993 that recommended passage of 
     state legislation requiring that all of Florida's 
     decisionmaking boards, councils, and commissions be half male 
     and half female by 1998. Justice Barkett defended the 
     Commission against charges that its report advocated a quota 
     system, by saying:
       ``It is not in the context of a quota system. It is 
     simply an acknowledgment that women make up one-half of 
     the population of this state.'' (St. Petersburg Times, 2/
     23/93.)
       If a rigid requirement that positions be filled according 
     to population is not a quota, then it is difficult to imagine 
     what would be. (Florida Governor Lawton Chiles stated that he 
     opposed the Commission proposal because it would create a 
     quota system. Orlando Sentinel Tribune, 2/23/93.) This issue 
     is not merely semantic: it may directly affect the breadth of 
     the remedial authority that Justice Barkett would believe 
     that she would have as a federal judge in cases of alleged 
     discrimination. The Supreme Court has ruled that the use of 
     preferential remedies and voluntary preferences is generally 
     disfavored, although it has upheld them in narrow 
     circumstances. If Justice Barkett cannot recognize a quota 
     for what it is, how can one have confidence that she will 
     properly construe Supreme Court precedents governing quotas 
     and other preferences and respect the limits that the Supreme 
     Court has placed on their use?
       Told that her views appeared to lead to pervasive race and 
     sex quotas, Justice Barkett did not dispute this. Indeed, she 
     appeared to embrace it (in the euphemism of 
     ``representation''): ``The goal of every women's group, 
     Senator, that I am aware of and the goal of every minority 
     group is that there be representation in policy-making bodies 
     that are going to affect their lives, whether it is in the 
     private sector or in the public sector. And I think that that 
     is a goal that is laudable. There are many different ways of 
     trying to achieve it, but I do not think that there is any 
     question that it should be achieved, and I am committed to 
     that.'' [184:3-11]
       Of course diversity in private and public employment and in 
     policymaking bodies is welcome. The critical question, 
     however, is whether it is to be pursued by nondiscriminatory 
     means or by the use of quotas and preferences. Justice 
     Barkett's statement appears to treat this fundamental 
     distinction as though it were insignificant.
       Even more disturbing is Justice Barkett's dissent in Foster 
     v. State, No. 76,639 (Fla. Apr. 1, 1993). In that case, 
     Foster, two young women, and another man, Lanier, drove to a 
     deserted area where one of the women was to make some money 
     by having sex with Lanier. As Lanier, who was very drunk, was 
     disrobing, Foster suddenly began hitting him and then held a 
     knife to Lanier's throat and sliced his neck. Foster and the 
     women then dragged the still-breathing Lanier into the bushes 
     and covered him with branches and leaves. Foster then took a 
     knife and cut Lanier's spine. Foster and the women then split 
     the money found in Lanier's wallet.
       Foster was convicted of murder and sentenced to death in 
     1975. On resentencing, the trial court, finding three 
     aggravating circumstances, again imposed the death penalty. 
     The Florida Supreme Court, by a 4-3 vote, rejected Foster's 
     claim that his death sentence was a product of racial 
     discrimination against black victims. (The court did remand 
     for resentencing on other grounds.)
       Justice Barkett, dissenting from this racial discrimination 
     ruling, would not accept the majority's determination that 
     Foster's statistical evidence purporting to show that white-
     victim defendants in Bay County were more likely to get the 
     death penalty than black-victim defendants failed to 
     establish a constitutional violation. (Lanier, evidently, was 
     white; Foster, according to newspaper accounts, was also 
     white.) Justice Barkett would have relied on the Florida 
     Constitution's Equal Protection Clause to reach a result 
     rejected by the U.S. Supreme Court in McCleskey v. Kemp, 481 
     U.S. 279 (1987), under the federal Equal Protection Clause. 
     In McCleskey, the Court ruled that a capital defendant 
     claiming a violation of the federal Equal Protection Clause 
     must show the existence of purposeful discrimination and a 
     discriminatory effect on him. According to Justice Barkett:
       (1) The McCleskey standard fails to address the problem of 
     ``unconscious discrimination.''
       (2) Statistical evidence of discriminatory impact in 
     capital sentencing that ``cannot be traced to blatant or 
     overt discrimination'' should establish a violation of 
     Florida's Equal Protection Clause.
       (3) This statistical evidence should be construed broadly 
     to include not only analysis of the disposition of first-
     degree murder cases, ``but also other information that could 
     suggest discrimination, such as the resources devoted to the 
     prosecution of cases involving white victims as contrasted to 
     those involving minority victims, and the general conduct of 
     a state attorney's office, including hiring practices and the 
     use of racial epithets and jokes.'' (Emphasis in italics.)
       (4) The defendant should have the initial burden of showing 
     the strong likelihood that discrimination influenced the 
     decision to seek the death penalty. ``Such discrimination 
     conceivably could be based on the race of the victim or on 
     the race of the defendant.'' Once the initial burden has been 
     met, ``the burden then shifts to the State to show that the 
     practices in question are not racially motivated.''
       The paralyzing effect that Justice Barkett's 
     proposed standard would have on the death penalty--and, 
     indeed, if taken to its logical conclusion, on the 
     criminal justice system generally--will be addressed in 
     another memorandum. For present purposes, what must be 
     emphasized are the broad-ranging implications that Justice 
     Barkett's disparate impact analysis could have on the 
     issue of quotas generally. Her focus on ``unconscious 
     discrimination'' shows that she rejects, for purposes of 
     Florida's Constitution, the basic principle under the 
     federal Constitution that discriminatory intent is an 
     essential element of an Equal Protection violation. Her 
     opinion also raises a legitimate concern that she might 
     adopt a view of statistical disparities under federal 
     statutes like the recently amended Title VII that 
     effectively mandates pervasive adoption of race and sex 
     quotas.


                    vii. concerns about impartiality

       In In re Constitutionality of Senate Joint Resolution 2G, 
     601 So.2d 543 (Fla. 1992), the Florida Supreme Court selected 
     from among six different modifications to a state legislative 
     redistricting plan. Writing ``dubitante,'' Barkett wrote that 
     she was ``loath to agree to any of the convoluted plans 
     submitted under these hurried circumstances. . . . If I had 
     to choose only among those presented, however, I would choose 
     the plan submitted by the NAACP simply because this is the 
     organization that had traditionally represented and promoted 
     the position that advances all minority interests.'' 
     (Emphasis in italics.)
       Justice Barkett's frank admission that she would give 
     special weight to a position based on who offered it rather 
     than on its intrinsic merits is very disturbing and appears 
     clearly at odds with the obligation of judicial impartiality.
       Justice Barkett claimed that her words were ``concededly 
     very inartful[]'' [174:15] and that what she ``was attempting 
     to say . . . was in rebuttal to a claim that the NAACP did 
     not adequately represent the interests of African 
     Americans.'' [175:1-4; see also 177:9-13] ``I can understand 
     in this case why you would read it the way you would read it. 
     It is inartful, and I wish that I had the opportunity to edit 
     that more than anything else that we have been talking 
     about.'' [175:12-14]
       Concern about Justice Barkett's impartiality also arose at 
     her hearing over her involvement with a trial lawyer's group, 
     the Academy of Florida Trial Lawyers, while the case of 
     University of Miami v. Echarte was pending. Specifically:
       (1) The Academy of Florida Trial Lawyers submitted an 
     amicus brief in this case in October 1991. The Trial Lawyers 
     brief (like other briefs submitted on behalf of one party) 
     argued that the cap on non-economic damages in medical 
     malpractice cases was unconstitutional.
       (2) In 1992, this same organization of trial lawyers 
     created an annual award named after her, the Rosemary Barkett 
     Award, to be given each year to a person who, in the view of 
     the trial lawyers, has made outstanding contributions to the 
     law. In November 1992, she agreed to present the first annual 
     award at the trial lawyers' annual convention, which took 
     place one week after her successful retention election.
       (3) In May 1993, she, in dissent, accepted the argument 
     that the cap on non-economic damages was unconstitutional.
       It does not seem at all consistent with her obligation to 
     maintain both the fact and the appearance of impartiality for 
     her to decide a case in which an organization that had named 
     an award after her had filed a brief. Indeed, her actions 
     would seem to have violated the ABA Code of Judicial Conduct. 
     Canon 2, subpart B states that a judge ``shall not lend the 
     prestige of judicial office to advance the private interests 
     of others; nor shall a judge convey or permit others to 
     convey the impression that they are in a special position to 
     influence the judge. . . .'' Canon 3, subpart E(1) states 
     that a judge should disqualify herself in a proceeding in 
     which her impartiality might reasonably be questioned.
       Justice Barkett stated that she understood the trial 
     lawyers' award to reflect the group's commitment to ``equal 
     justice under the law'' [179:20-21] and not to have anything 
     to do with its ``private interests'' [181:7]. In any event, 
     the trial lawyers' amicus brief in Echarte clearly advanced 
     their private interests, and her participation in that case 
     would seem to give rise to an appearance of lack of 
     impartiality.

                          ____________________