Franklin v. State

Summary

The Supreme Court of Florida considered whether chapter 99-188, the Three-Strike Violent Felony Offender Act, violated the Florida Constitution’s single-subject clause. The court held that the Act did not violate article III, section 6, and upheld Franklin’s habitual-felony-offender sentence. The opinion clarified how courts should identify an act’s single subject and determine whether its provisions are properly connected to that subject.

Holdings

1. A person adversely affected by sentencing amendments contained in a chapter law has standing to challenge the law under article III, section 6, even if the person was not directly affected by every challenged provision.
2. The single subject of a legislative act ordinarily is determined from the short title, specifically the language following the customary phrase "an act relating to" and preceding the indexing of the act's provisions.
3. A connection between a provision and an act's subject is proper if it is natural or logical, or if there is a reasonable explanation showing that the provision is necessary to the subject or tends to make effective or promote the legislation's objects and purposes.
4. Sections 11 and 13 were properly connected to the Act's single subject of sentencing and therefore did not violate article III, section 6.
5. Chapter 99-188, Laws of Florida, does not violate the single subject clause of article III, section 6 of the Florida Constitution.

Questions Presented

1. Whether Franklin had standing to challenge chapter 99-188 under the single subject clause even though he was not directly affected by sections 11 and 13.
2. How courts should identify the single subject of a legislative act under article III, section 6 of the Florida Constitution.
3. What test governs whether provisions of an act are matters properly connected with its single subject.
4. Whether sections 11 and 13 of chapter 99-188 were properly connected to the Act's subject of sentencing.
5. Whether chapter 99-188 violated article III, section 6 of the Florida Constitution.

Disposition

approved