Christin Bilotti: Verdict, Juror Appeal, and Case Status

The Christin Bilotti case is a Broward County, Florida murder prosecution in which Bilotti, then 17, was convicted of second-degree murder for helping lure her ex-boyfriend Richard Rojas to her family’s Davie home in July 2005, where her father’s associate shot and killed him. She was sentenced in 2015 to 30 years in prison. Her conviction has survived a reversal that was itself overturned, and in October 2025 she petitioned the U.S. Supreme Court to review a jury-selection issue from her trial.¹

What Happened in July 2005

Just after 1:30 a.m. on July 12, 2005, Richard Rojas drove to a townhome in the Chelsea at Ivanhoe community in Davie, Florida, where Christin Bilotti lived with her mother. He was met at the door by John Pacchiana, a manager at a Miami strip club owned by Christin’s father, Michael Bilotti. A verbal confrontation turned into a brief physical struggle. Testimony at trial described the fight as already over, with Rojas standing in the walkway outside the house, when Pacchiana shot him twice in the face and neck. Rojas, 19, died at the scene.²

Rojas had been Christin’s boyfriend until they broke up in June 2005. Witnesses at trial described him as controlling and said he had shown up at her home uninvited in the middle of the night after the breakup.³

Christin Bilotti’s Alleged Role

Prosecutors argued that the killing was the product of a coordinated plot triggered by a false rape claim. On the day of the shooting, Christin told her mother, Louise Bilotti, that Rojas had raped her. Louise testified she believed her daughter and offered to call the police, but Christin declined. No charges for rape were ever filed against Rojas.⁴

According to the prosecution, Michael Bilotti learned of the accusation, traveled to the house, said of Rojas “he’s dead,” and directed Pacchiana to wait there. Julio “Eddie” Arce, who was then dating Christin, called Rojas and provoked him into driving from his home in Kendall to the Davie townhome under the pretense of a fight. Phone records placed Christin in contact with Rojas in the hours before the shooting. Prosecutors argued she could have stopped the killing at any point by warning Rojas or by telling her father the rape allegation was false.⁵

What the Defense Argued

The defense disputed that there was any plot at all. Pacchiana’s lawyers said he feared for his life and fired in self-defense at the front door. They pointed to testimony that Rojas was controlling, carried large amounts of cash, and kept a gun in his car, and they said Michael Bilotti had asked Pacchiana to stay at the home because Rojas had threatened to return and harm Christin’s younger brother.²

That account was undercut at trial by Richard Corbin, a former co-defendant who had pleaded guilty to accessory charges. Corbin testified that the physical struggle had already ended before Pacchiana drew his gun and that Rojas was not trying to enter the house when he was shot.² None of the three defendants took the stand.³

Verdict and Sentence

The three defendants were tried together in Broward Circuit Court in May 2015 before Judge Jeffrey R. Levenson. On May 29, 2015, the jury convicted Michael Bilotti and John Pacchiana of first-degree murder and conspiracy to commit first-degree murder. Both received mandatory life sentences. The jury convicted Christin Bilotti of second-degree murder and acquitted her of conspiracy.⁶

Because Christin had been 17 at the time of the crime, the court was required under the U.S. Supreme Court’s 2012 decision in Miller v. Alabama to weigh her immaturity and potential for rehabilitation before imposing sentence. Before sentencing, one juror emailed Judge Levenson to say the verdict “was especially difficult for me” and that although Christin “led Richard to the home, she did not mean for him to be killed,” asking the judge to “be fair when giving her sentence.”⁵

On August 28, 2015, Judge Levenson sentenced her to 30 years in prison, to be followed by two years of community control and eight years of probation.⁷

The Jehovah’s Witness Juror and the Appeals

Every appeal in the case has turned on a single moment during jury selection. The prosecution used a peremptory strike to remove a Black woman who was a Jehovah’s Witness. She had said she wanted to serve, had served on a civil jury before, and had confirmed she could be impartial and apply the beyond-a-reasonable-doubt standard.⁸

The prosecutor’s stated reason was her religion: “She’s a Jehovah Witness. I’ve never had one say, and I highlighted it, they’ve always said they can’t sit in judgment.” Judge Levenson allowed the strike as a “genuine non-race-based reason” and added, “it would almost be malpractice for a prosecutor to let someone on the jury like that.”⁸

On February 14, 2018, Florida’s Fourth District Court of Appeal reversed all three convictions in Pacchiana v. State, holding that striking a juror based solely on religious affiliation violated both the U.S. and Florida Constitutions and amounted to an impermissible “religious test.” Christin’s conviction was reversed in a companion opinion.⁹¹⁰

The Florida Supreme Court then reversed course. On January 9, 2020, in State v. Pacchiana, it quashed the Fourth DCA’s ruling without deciding whether the constitutional rule against race-based jury strikes announced in Batson v. Kentucky extends to religion. Instead, it held that the defense had failed to preserve the religion-based objection at trial, having initially framed it as race-based and not filed a written motion raising religious discrimination until five days after the juror was excused.¹¹¹² The same ruling was applied to Christin’s case on May 22, 2020, and the Fourth DCA affirmed her conviction and sentence on June 17, 2020. There was no retrial.¹³

Bilotti then argued in post-conviction proceedings that her trial attorney had been ineffective for failing to preserve the objection properly. Florida courts denied that claim, and she moved into federal court with a habeas corpus petition. On April 11, 2025, the U.S. Court of Appeals for the Eleventh Circuit affirmed the denial of habeas relief, reasoning that the law on whether Batson extends to religion-based strikes was unsettled at the time of her 2015 trial, so her lawyer’s performance was not constitutionally deficient.¹⁴

Where the Case Stands Now

On October 15, 2025, Bilotti filed a petition for a writ of certiorari with the U.S. Supreme Court, asking it to decide whether Batson prohibits peremptory strikes based on religious affiliation.¹ The Supreme Court has never resolved that question, and lower courts are split. Justice Clarence Thomas flagged the issue as one the Court should take up as early as 1994.¹⁵ Whether the Court will hear her case has not been decided.

Separately, Bilotti has argued that because she was a juvenile at the time of the offense, she is entitled to judicial review of her sentence after 15 years under Florida Statute Section 921.1402, which applies to juvenile offenders sentenced to more than 15 years who did not kill, intend to kill, or attempt to kill the victim. A dissenting judge at the Fourth DCA agreed, writing that juvenile homicide offenders should have a “meaningful opportunity for release based on demonstrated maturity and rehabilitation.” The majority did not adopt that view, and the trial court’s denial of her motion for review stands.¹⁰

1
U.S. Supreme Court. Bilotti v. Florida Department of Corrections, No. 25-478
2
Sun-Sentinel. Former Defendant: Victim Not Fighting When Shot
3
Orlando Sentinel. Bilotti Murder Trial Winds Down
4
Sun-Sentinel. Woman Testifies at Murder Trial of Her Daughter and Ex-Husband
5
Orlando Sentinel. Juror to Judge: Be Fair When Sentencing Christin Bilotti
6
Sun-Sentinel. Jury Convicts Father, Daughter and Strip Club Manager in 2005 Murder
7
Sun-Sentinel. Dad, Daughter, Friend Sentenced for 2005 Murder
8
FindLaw. Pacchiana v. State
9
Sun-Sentinel. Murder Convictions Overturned Because Jehovah’s Witness Not Allowed to Serve on Jury
10
Fourth District Court of Appeal. Bilotti v. State, No. 4D15-3559
11
Sun-Sentinel. Florida Supreme Court Sidetracks Retrials in Davie Murder Case
12
FindLaw. State v. Pacchiana
13
Justia. Bilotti v. State, No. 15-3559
14
U.S. Court of Appeals for the Eleventh Circuit. Bilotti v. Florida Department of Corrections, No. 23-11759
15
Loyola University Chicago Law Journal. Peremptory Challenges and Religion: The Unanswered Prayer for a Supreme Court Opinion