Background
On July 1, 2026, Florida’s First District Court of Appeal issued its decision affirming the conviction of Charles Adelson—the fourth of five defendants convicted in connection with the 2014 murder-for-hire killing of Florida State University law professor Dan Markel. Adelson was convicted of first-degree murder, conspiracy to commit murder, and solicitation to commit murder following a jury trial, and was sentenced to life in prison plus two consecutive thirty-year terms.
On appeal, Adelson raised four claims of trial court error. Two of them—the change-of-venue motion and the motion to strike the entire jury panel—received detailed analysis from the court.
The Change-of-Venue Argument
Both the federal and Florida constitutions guarantee a criminal defendant the right to a fair trial before an impartial jury. In high-profile cases, a defendant can ask the court to move the trial to a different county if pretrial publicity has been so extensive and prejudicial that seating a fair jury in the original county is impossible.
Adelson argued that media coverage of the Markel murder was so pervasive in Leon County that an unbiased jury could not be found there. During jury selection, 130 prospective jurors were individually questioned. Of those, 96 had heard about the case and 54 had formed an opinion about Adelson’s guilt—the court excused all 54.
The First DCA rejected the venue claim on two grounds. First, Adelson’s attorney never filed the venue motion in writing as required, and never renewed the motion before the jury was sworn—in fact, when directly asked by the judge whether he accepted the jury, Adelson said yes. Second, even reviewing for fundamental error, the court found the 12 jurors who were actually seated had minimal knowledge of the case, had not formed opinions, and committed to being fair and impartial.
The Jury-Panel Argument
Adelson also argued the trial court should have dismissed the entire jury pool after some prospective jurors ignored instructions not to discuss the case while waiting in the assembly room. One prospective juror reported overhearing a comment that Adelson was guilty.
The First DCA rejected this claim as well. The motion to strike was made orally rather than in writing as required by court rules, and was not renewed before the jury was sworn. The trial court had also offered defense counsel an opportunity to review assembly room recordings to investigate the extent of the conversations—an offer the defense declined. Even under a fundamental error standard, the court concluded the overheard comments were not prejudicial enough to require dismissing the entire panel.
Why This Matters
This decision is a textbook illustration of why preservation matters in high-profile criminal cases. Both the venue challenge and the jury-panel challenge failed not primarily because the underlying concerns were invalid, but because they were not raised and renewed in the precise procedural manner the rules require. Pretrial publicity and jury impartiality are legitimate constitutional concerns—but raising them correctly, and at every required stage, is what gives those arguments teeth on appeal.
Read the full opinion: Adelson v. State, No. 1D2024-0004, First District Court of Appeal (July 1, 2026)
How Sanchez Vaughn Trial Lawyers Can Help
High-profile cases bring unique challenges: extensive media coverage, inflamed community sentiment, and jury pools that may be difficult to keep neutral. Sanchez Vaughn Trial Lawyers handles serious criminal cases throughout Tampa Bay and knows how to evaluate, file, and preserve change-of-venue motions and jury-selection challenges the right way—from the written motions to the renewals that keep every argument available for appeal. If you are facing charges in a case that has drawn public attention, we are ready to help.