## Facts

- Oscar Quindo Florida lived in a shared home with two other men, including Alfonso Ranan.
- Florida and Ranan had an ongoing hostile relationship and did not get along.
- A few days before the killing, Florida and Ranan fought, and Ranan hit Florida hard enough to give Florida a black eye.
- On the day Ranan died, Florida and Ranan spent time at a relative’s house.
- When Florida told Ranan he did not have enough room in his car to take Ranan home, Ranan again challenged Florida to fight.
- Florida and Ranan fought and were separated by others.
- After returning home, Ranan started another fight with Florida; the situation calmed, and Florida went to bed.
- Later that night, Ranan woke Florida by grabbing him, yelling obscenities, and challenging him to a “fight to the death.”
- Ranan put Florida in a chokehold; Florida broke free.
- Florida then grabbed a knife, chased Ranan out of the house, stabbed him, and returned inside.
- Ranan died from the stab wound.
- Florida was charged with aggravated murder under Guam law, defined as intentional murder committed with premeditation.
- Before the case went to the jury, Florida moved for a judgment of acquittal on the aggravated-murder count, arguing the prosecution failed to present sufficient evidence of premeditation.
- The trial court denied the motion and instructed the jury on premeditation, including that the time required to premeditate can vary with the person and circumstances.
- The jury acquitted Florida of aggravated murder but convicted him of murder (a lesser offense not requiring premeditation), and Florida appealed.

## Issues

1. Whether the evidence, viewed in the light most favorable to the prosecution, was sufficient to allow a reasonable jury to find premeditation and thus to deny Florida’s motion for judgment of acquittal on the aggravated-murder charge.
2. Whether submitting the aggravated-murder charge to the jury and instructing on premeditation required reversal where the jury acquitted on aggravated murder but convicted on murder.

## Decision

- The Appellate Division affirmed the judgment.
- The court held the trial court did not err in denying Florida’s motion for judgment of acquittal on aggravated murder because a reasonable jury could infer premeditation from the circumstances.
- The court concluded that instructing the jury on premeditation and permitting consideration of the aggravated-murder charge did not warrant reversal of the murder conviction, particularly given the jury’s acquittal on aggravated murder.

## Legal Principles

- A motion for judgment of acquittal based on insufficient evidence is properly denied if, viewing the evidence in the light most favorable to the prosecution, a rational juror could find the elements of the charged offense beyond a reasonable doubt.
- Premeditation may be proved by circumstantial evidence and reasonable inferences drawn from a defendant’s conduct before and during the killing.
- Premeditation does not require a long period of planning; the time needed to form a premeditated intent may be brief and depends on the individual and the circumstances.
- When a jury acquits on a greater offense (here, aggravated murder requiring premeditation) but convicts on a lesser offense (murder without premeditation), submission of the greater charge and related instructions generally do not justify reversing the lesser-offense conviction absent a showing of prejudicial effect on the verdict.

## Conclusion

In *People v. Florida*, the Appellate Division upheld Florida’s murder conviction, ruling that the evidence allowed a reasonable jury to consider whether Florida acted with premeditation for aggravated murder (given his breaking free, arming himself, and pursuing Ranan before the fatal stabbing), and that any submission of the aggravated-murder count and the premeditation instruction did not invalidate the murder verdict, especially since the jury rejected aggravated murder.


People v. Florida, 1997 WL 209044 (1997)