MICHAEL WAYNE LYONS, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.
Michael Wayne Lyons appeals his battery conviction on the ground that the trial court improperly excluded defense cross-examination regarding whether the victim had a pending claim under the Florida Crimes Compensation Act. The appellate court affirms, holding that such evidence is irrelevant and that the Crimes Compensation Act was statutorily designed to have no bearing on criminal proceedings.
The trial court correctly sustained the objection. Evidence regarding a victim's pending claim under the Crimes Compensation Act is irrelevant to any issue at trial and was properly excluded.
[1] The existence or nonexistence of a claim under the Florida Crimes Compensation Act is irrelevant to any issue in a criminal trial.
[2] The Florida Crimes Compensation Act is designed to provide financial assistance to victims of crime and is drafted to have no bearing on criminal proceedings.
Previewing 2 of 3 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“Claims shall be investigated and determined, regardless of whether the alleged criminal has been apprehended or prosecuted for, or convicted of, any crime based upon the same incident, or has been acquitted or found not guilty of the crime in question owing to lack of criminal responsibility or to other legal exemption or defense.”
Statutory language demonstrating that the Crimes Compensation Act is independent of criminal proceedings
Previewing 1 of 2 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceLyons was convicted of battery. During trial, defense counsel sought to cross-examine the battery victim about whether he had a pending claim under th…
The full statement of facts, procedural history, and disposition for this case are member content.
Join FLexlaw to unlock all legal intelligence© FLexlaw, Inc. — AI-generated enrichments are proprietary. All rights reserved.
Explore caselaw by topic → Browse Victim Credibility cases and more on FLexlaw
RYDER, Judge.
Appellant, Michael Wayne Lyons, appeals from a judgment and sentence for battery.
Appellant’s only point on appeal is that the trial court erred in precluding defense counsel from cross-examining the battery victim regarding whether he had a pending claim under the Florida Crimes Compensation Act.
The Florida Crimes Compensation Act, Chapter 960, Florida Statutes (1979), was enacted by the legislature to provide governmental financial assistance for victims of crimes who suffer personal injury as a direct result of a criminal act. Section 960.-09(3) of the act specifically provides that the outcome of any criminal proceeding shall have no bearing upon the consideration of any claim under the act:
(3) Claims shall be investigated and determined, regardless of whether the alleged criminal has been apprehended or prosecuted for, or convicted of, any crime based upon the same incident, or has been acquitted or found not guilty of the crime in question owing to lack of criminal responsibility or to other legal exemption or defense.
In light of this statutory provision, we hold that the trial court correctly sustained the objection to testimony regarding the existence of a claim under the Crimes Compensation Act. The existence or nonexistence of such a claim was irrelevant to any issue at trial. The Crimes Compensation Act was carefully drafted to have no bearing on any criminal proceeding. Certainly the legislature did not intend the Crimes Compensation Act could be used as a means of attacking the credibility of victims who testify at trial.
Accordingly, the judgment and sentence of the trial court are affirmed.
SCHEB, Acting C. J., and CAMPBELL, J., concur.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By
-
Wooten v. State, 464 So. 2d 640 (Fla. 3d DCA 1985)…N.J.Super. 93, 395 A. 2d 878 (1978), cert. denied, 74 N.J. 494, 401 A. 2d 249 (1979), simply hold the error to be non-prejudicial or harmless under the circumstances of the case, which circumstances are not revealed in the opinions. Lyons v. State, 384 So. 2d 982 (Fla. 2d DCA 1980), which the State calls "strikingly similar” to the case at hand, is not similar at all. There, the defendant was precluded from cross-examining the battery victim regarding whether he had a pending claim under the Florida Crimes C…