## Facts

- Melvin Stacy Jenkins lived with his family in two small rented trailers separated by a narrow, shared driveway in a mobile home park in Hillsborough County, Florida.
- After Jenkins’s daughter reported a dispute with a woman nearby, the woman’s boyfriend, Bryan Cerezo, came to the family’s other trailer, shouting and banging on the door.
- Jenkins came outside and repeatedly told Cerezo to leave; Cerezo refused.
- Three disinterested neighbors observed Cerezo pacing in the driveway, threatening to kill Jenkins and his family, and trying to provoke a fight.
- Cerezo remained the aggressor and struck Jenkins in the face, causing Jenkins to stumble backward.
- Jenkins drew a six-inch work knife from his belt; Cerezo said he had a gun and was going to shoot Jenkins.
- When Cerezo charged or lunged again, Jenkins raised the knife, inflicting a single fatal stab wound to Cerezo’s chest.
- Witnesses testified Jenkins had little space to retreat because of the narrow driveway and trailer layout.
- A jury convicted Jenkins of manslaughter with a deadly weapon; the trial court denied his motion for judgment of acquittal, rejecting self-defense.

## Issues

1. Whether the evidence was legally sufficient to permit the State to overcome Jenkins’s prima facie claim of self-defense and sustain a manslaughter conviction.
2. Whether the narrow common driveway between the two rented trailers was part of Jenkins’s residence or immediate surrounding premises such that he had no duty to retreat before using deadly force when violently assaulted there.

## Decision

- The appellate court reversed the judgment and sentence for manslaughter.
- The court held Jenkins established self-defense and the State failed to present legally sufficient evidence to rebut it.
- The court held the common driveway constituted part of Jenkins’s premises for purposes of the castle doctrine, eliminating any duty to retreat before using deadly force when violently assaulted there.

## Legal Principles

- On a motion for judgment of acquittal, evidence is viewed in the light most favorable to the State, but a conviction cannot stand if the evidence is legally insufficient to support guilt beyond a reasonable doubt.
- When a defendant presents a prima facie claim of self-defense, the State must present legally sufficient evidence to disprove self-defense.
- Under Florida’s castle doctrine (as applied in this case), there is no duty to retreat before using deadly force when a person is violently assaulted in the person’s residence or immediate surrounding premises.
- “Immediate surrounding premises” may include areas functionally part of the residential space, even if not within the dwelling’s walls.

## Conclusion

Because the undisputed and corroborated evidence showed Cerezo was the aggressor, threatened deadly harm, struck Jenkins, and then advanced again after claiming he had a gun, and because the confrontation occurred on Jenkins’s protected premises where no duty to retreat applied, the State did not present legally sufficient evidence to negate self-defense; the manslaughter conviction was reversed.


Jenkins v. State, 942 So. 2d 910 (Fla. Dist. Ct. App. 2d Dist. 2006)