Duval County

Mr. Garrett was sentenced to life in prison for the first-degree murder of Jerry Ford, who was fatally shot in 2011. On appeal, Mr. Garrett, who said he acted in self-defense,
argued that the jury was wrongly instructed to consider that illegal activity at the time of the shooting, such as firearm possession by a felon, meant he had a duty to retreat from
a confrontation with Mr. Ford. The First District Court of Appeal agreed that the jury instruction was improper but ruled that the mistake was not a fundamental error. This
Court accepted jurisdiction based on express and direct conflict between the decision by the 1st DCA and rulings by the Fourth District Court of Appeal on the same legal
issue.