Answer Brief of Appellee - Florida State University College of Law

Sammie Hoskins is the appellant’s younger brother. (R1246).
Johnnie taught him how to drive and do farm work. Their house
was very cold in the winter, very hot in the summer. After
Johnnie moved out, he would still contribute money to the
household, “to make sure ... we had something to eat at home.”
(R1247).
Johnnie was very loving toward his entire family. (R1249).
Jesse Balanks is Hoskins’ uncle. (R1257). He lived close to
Johnnie while growing up and they farmed together. (R1257).
Johnnie got along well with his family, although he argued with
his father sometimes. (R1259). 10
Johnnie Mae Hoskins, defendant’s mother, said he was not a
problem child, he worked on farms and was paid well. (R1264,
1266). He contributed to the family financially, and helped take
care of the family pets. (R1267).
Rufus Hoskins, the defendant’s brother, said Johnnie “was
kind of like a father figure to us.” He taught his siblings many
things and was not violent. They all had a very loving
relationship. (R1270-71, 1272). Johnnie also had a good
relationship with his father. However, Johnnie would intervene
when their father became drunk and violent and would “try to
calm things down.” (R1273-74). Johnnie dropped out of school to
work and help the family out financially. (R1276).
10
Hoskins’ father drank and argued with Hoskins’ mother. (R1259).
16