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 statute requires a causal connection between the defendant's felony and the victim's death. It nevertheless approved the affirmance of Dean's convictions and quashed the PRR sentencing determination because the record did not establish that Dean met the statutory PRR requirements, remanding for resentencing. Justice Quince, concurring in result only, would have held that manslaughter was not a necessarily lesser included offense, while Justice Pariente, concurring in part and dissenting in part, would have required a new trial based on the failure to give the manslaughter instruction.