CHARLES CLEAVER YOUNG, APPELLANT,
v.
THE 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.
Florida appellate court reversed a manslaughter conviction because the trial court improperly restricted cross-examination of the key prosecution witness on matters affecting credibility, violating the defendant's Sixth Amendment confrontation right.
A trial court's pretrial motion in limine that restricts cross-examination of a key prosecution witness on matters crucial to credibility violates the defendant's Sixth Amendment right of confrontation and requires reversal.
[1] A trial court's pretrial motion in limine that restricts a defendant's cross-examination of a key prosecution witness on matters affecting credibility violates the Sixth…
Previewing 1 of 1 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“defendant's sixth amendment right of confrontation of witnesses was violated by trial court's limiting defense counsel's cross-examination of prosecution witness in attempt to demonstrate possible bias”
Court citing Davis v. Alaska for the principle that restricting cross-examination on witness bias violates confrontation rights
Young was convicted of manslaughter with a firearm by jury verdict. The trial court granted the state's pretrial motion in limine, which restricted 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 Bias Of Witnesses cases and more on FLexlaw
PER CURIAM.
The appellant appeals a judgment of conviction and sentence for manslaughter with a firearm, pursuant to a jury verdict finding him guilty of such charge.
One of the points relied upon by appellant for reversal is that the trial court erred in granting the state’s pretrial motion in limine, thereby restricting appellant’s right to cross-examine the key prosecution witness on matters crucial to that witness’s credibility. We find merit in this contention and reverse and remand for a new trial. See Davis v. Alaska, 415 U.S. 308, 94 S.Ct. 1105, 39 L.Ed.2d 347 (1974) (defendant’s sixth amendment right of confrontation of witnesses was violated by trial court’s limiting defense counsel’s cross-examination of prosecution witness in attempt to demonstrate possible bias by showing witness’s probationary status as juvenile delinquent); Moreno v. State, 418 So. 2d 1223, 1226 (Fla. 3d DCA 1982) (refusal to allow defendant to question state’s witnesses about criminal charges brought against them, for which they had been granted immunity in exchange for their testimony, was reversible error); Crespo v. State, 344 So. 2d 598 (Fla. 3d DCA 1977) (trial court committed reversible error in precluding defense counsel from cross-examining state’s witness regarding a criminal charge or prosecution then pending against him).
In view of our disposition, we decline to address the additional points raised by appellant, as they are based on matters which should not recur on retrial.
Reversed and remanded for a new trial.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By
-
Novaton v. State, 634 So. 2d 607 (Fla. 1994)…otherwise arguably defective sentences when they have been voluntarily accepted by the defendant as part of a mutually advantageous agreement with the state.” Id. at 728 (citing Madrigal v. State, 545 So. 2d 392 (Fla. 3d DCA 1989); Jacobs v. State, 522 So. 2d 540 (Fla. 3d DCA), review denied, 531 So. 2d 1353 (Fla.1988); Preston v. State, 411 So. 2d 297 (Fla. 3d DCA), review denied, 418 So. 2d 1280 (Fla.1982); Smith v. State, 345 So. 2d 1080 (Fla. 3d DCA), cert. denied, 353 So. 2d 678 (Fla.1977)). In its fina…
-
Novaton v. State, 610 So. 2d 726 (Fla. 3d DCA 1992)…many other contexts as well, this court and others have upheld otherwise arguably defective sentences when they have been voluntarily accepted by the defendant as part of a mutually advantageous agreement with the state.3 See, e.g., Jacobs v. State, 522 So. 2d 540 (Fla. 3d DCA 1988) (denial of motion to correct allegedly illegal sentences affirmed as part of negotiated plea), review denied, 531 So. 2d 1353 (Fla.1988); Preston v. State, 411 So. 2d 297, 298-99 (Fla. 3d DCA 1982) (defendant who should have been…
-
Lillyman v. Dep't OF Hwy. Safety & Motor Vehicles, 645 So. 2d 113 (Fla. 5th DCA 1994)…1321 (Fla. 3d DCA 1993) (erroneous exclusion of testimony required remand for further proceedings). The remedy is similar to granting a new trial when an error is made during trial regarding the admissibility of testimony. See, e.g., Young v. State, 522 So. 2d 540 (Fla. 3d DCA 1988) (remand for new trial required where court improperly restricted defendant’s cross-examination of key prosecution witness on matters crucial to witness’ credibility); Sadler v. State, 509 So. 2d 1139 (Fla. 5th DCA 1987) (precludin…
Previewing 3 of 10 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Davis v. Alaska, 415 U.S. 308 (U.S. 1974)
- Moreno v. State, 418 So. 2d 1223 (Fla. 3d DCA 1982)
- Artemio Crespo v. State, 344 So. 2d 598 (Fla. 3d DCA 1977)