NATHANIEL LANE, APPELLANT,
v.
THE STATE OF FLORIDA, APPELLEE
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Florida appellate court affirmed defendant's robbery and attempted first-degree murder convictions, holding that any error in admitting victim identification evidence was harmless and that the trial court properly restricted cross-examination regarding the victim's drug activity and a witness's undisclosed mental evaluation.
The trial court did not err in admitting victim identification evidence or restricting cross-examination, as any evidentiary error was harmless beyond a reasonable doubt and the excluded evidence lacked sufficient relevancy.
[1] Any error in admitting victim identification evidence is harmless beyond a reasonable doubt when overwhelming evidence of guilt is presented at trial.
[2] A trial court does not abuse its discretion in excluding cross-examination evidence regarding a victim's drug activity and a witness's undisclosed mental evaluation when…
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Join FLexlaw to unlock all legal intelligenceNathaniel Lane was convicted of robbery and attempted first-degree murder. The victim identified Lane as the perpetrator, and the state presented iden…
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PER CURIAM.
The defendant Nathaniel Lane appeals his criminal convictions and sentences entered below for robbery and attempted first degree murder. Two points are raised on appeal. First, it is urged that the trial court erred in denying the defendant’s motion to suppress the victim’s identification of the defendant. Second, it is urged that the trial court erred in restricting the cross-examination of the state’s identification witnesses. We are unpersuaded that these points merit a reversal and affirm.
As to the first point, our review of the record shows that the error, if any, in admitting the complained-of evidence was harmless beyond a reasonable doubt in view of the other overwhelming evidence of guilt presented below. See Chapman v. California, 386 U.S. 18, 22-24, 87 S.Ct. 824, 827-28, 17 L.Ed.2d 705, 709-11 (1967); § 924.33, Fla.Stat. (1983). As to the second point, the defendant was precluded from establishing that the victim was selling marijuana just prior to the robbery, and that another eyewitness had previously undergone a mental evaluation with undisclosed results. The trial court did not abuse its discretion in concluding that the minimal relevancy, if any, of this evidence was far outweighed by its prejudicial impact, so as to preclude its admission in evidence. Sireci v. State, 399 So. 2d 964 (Fla.1981), cert. denied, 456 U.S. 984, 102 S.Ct. 2257, 72 L.Ed.2d 862 (1982); Ho Yin Wong v. State, 359 So. 2d 460 (Fla.3d DCA), cert. denied, 364 So. 2d 886 (Fla.1978).
The judgments of conviction and sentences under review are in all respects
Affirmed.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Chapman v. California, 386 U.S. 18 (U.S. 1967)
- Sireci v. State, 399 So. 2d 964 (Fla. 1981)
- Federated Publ'ns, Inc. v. Swedberg, 456 U.S. 984 (U.S. 1982)
- Jacks v. Duckworth, 456 U.S. 984 (U.S. 1982)
- HO YIN Wong v. State, 359 So. 2d 460 (Fla. 3d DCA 1978)