Christopher Dean, Petitioner v. State of Florida, Respondent

Summary

The court held that manslaughter is a necessarily lesser included offense of second-degree felony murder because the felony-murder elements necessarily include a defendant act causally connected to the victim's death. It nevertheless approved the affirmance of Dean's murder and burglary convictions, while quashing the PRR sentencing determination because the record lacked evidence establishing his eligibility and remanding for resentencing. Justice Polston concurred in full, Justice Quince concurred in the result but rejected the lesser-included-offense holding, and Justice Pariente concurred in part and dissented from affirmance of the convictions, concluding that a new trial was required.