JAMAEL BELL
v.
STATE OF FLORIDA
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Jamael Bell appealed a conviction from the Circuit Court for the Fifteenth Judicial Circuit in Palm Beach County. The Fourth District Court of Appeal affirmed the conviction, rejecting Bell's constitutional challenges regarding statutory provisions at issue.
The conviction is affirmed. The court rejected Bell's constitutional challenges to section 790.23 and related statutes, consistent with established precedent.
[1] A court of appeal lacks authority to overrule United States Supreme Court precedent establishing the constitutionality of six-member juries in criminal proceedings.
Previewing 1 of 1 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“See, inter alia, Carter v. State, 423 So. 3d 425 (Fla. 4th DCA 2025) (citing cases that rejected challenges to the constitutionality of section 790.23)”
Establishes that the court relied on precedent rejecting constitutional challenges to section 790.23
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Join FLexlaw to unlock all legal intelligenceJamael Bell was convicted in the Circuit Court for the Fifteenth Judicial Circuit, Palm Beach County. The case involved statutory provisions that Bell…
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DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA FOURTH DISTRICT
JAMAEL BELL, Appellant,
V.
STATE OF FLORIDA, Appellee.
No. 4D2025-1258 [April 8, 2026]
Appeal from the Circuit Court for the Fifteenth Judicial Circuit, Palm Beach County; Sherri L. Collins, Judge; L.T. Case No. 502023CF006805A. Daniel Eisinger, Public Defender, and Jeffrey L. Anderson, Assistant Public Defender, West Palm Beach, for appellant.
James Uthmeier, Attorney General, Tallahassee, and Luke R. Napodano, Senior Assistant Attorney General, West Palm Beach, for appellee.
PER CURIAM.
Affirmed. See, inter alia, Carter v. State, 423 So. 3d 425 (Fla. 4th DCA 2025) (citing cases that rejected challenges to the constitutionality of section 790.23); Guzman v. State, 350 So. 3d 72, 73 (Fla. 4th DCA 2022) (noting that this court has no authority to overrule the United States Supreme Court precedent that held the use of a jury with only six members was constitutional).
KLINGENSMITH, SHAW and LOTT, JJ., concur. * * *
Not final until disposition of timely-filed motion for rehearing.
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Cited By
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Jamael Bell v. State (Fla. 4th DCA 2026)…istant Public Defender, West Palm Beach, for appellant. James Uthmeier, Attorney General, Tallahassee, and Luke R. Napodano, Senior Assistant Attorney General, West Palm Beach, for appellee. PER CURIAM. Affirmed. See, inter alia, Carter v. State, 423 So. 3d 425 (Fla. 4th DCA 2025) (citing cases that rejected challenges to the constitutionality of section 790.23); Guzman v. State, 350 So. 3d 72, 73 (Fla. 4th DCA 2022) (noting that this court has no authority to overrule the United States Supreme Court prece…
Authorities Cited
- Guzman v. State, 350 So. 3d 72 (Fla. 4th DCA 2022)
- Jamael Bell v. State (Fla. 4th DCA 2026)