PABLO LYLE
v.
THE STATE OF FLORIDA
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This case concerns whether Pablo Lyle was entitled to pre-trial immunity from prosecution under Florida's Stand Your Ground law after striking a victim who later died. The appellate court affirmed the trial court's denial of immunity, finding the state met its burden to overcome the self-defense claim.
No, Pablo Lyle was not entitled to pre-trial immunity. The appellate court affirmed the trial court's decision, finding that the State met its burden of proving by clear and convincing evidence that Lyle was not entitled to immunity.
[1] A pre-trial immunity hearing under Florida's Stand Your Ground law requires the prosecution to prove by clear and convincing evidence that the defendant is not entitled t…
[2] Appellate review of a trial court's factual findings in a Stand Your Ground immunity hearing is for competent substantial evidence, while legal conclusions are reviewed d…
Previewing 2 of 4 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“In a criminal prosecution, once a prima facie claim of self-defense immunity from criminal prosecution has been raised by the defendant at a pretrial immunity hearing, the burden of proof by clear and convincing evidence is on the party seeking to overcome the immunity from criminal prosecution provided in subsection (1).”
This quote establishes the burden of proof on the prosecution in Stand Your Ground immunity hearings.
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligencePablo Lyle was charged with manslaughter after striking a victim with his fist, causing the victim to fall into a coma and later die. Lyle moved for p…
The full statement of facts, procedural history, and disposition for this case are member content.
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HENDON, J.
Pablo Lyle (the “Petitioner”) challenges the order denying his pre-trial motion seeking immunity from prosecution pursuant to section 776.032, Florida Statutes (2017) (Florida’s Stand Your Ground law, effective June 2017). The Petitioner was charged by information with manslaughter as a result of striking the victim in the head with his fist. The victim went into a coma and later died. Lyle moved to dismiss the charge under section 776.032. At the conclusion of the August 2019 pre-trial immunity hearing, the trial judge articulated his reasons for denying immunity and the written order was rendered in September 2019. This Court stayed proceedings until the Florida Supreme Court decided the issue of the statute’s retroactivity in Love v. State, 247 So. 3d 609 (Fla. 3d DCA 2018).1
Under our appellate standard of review, the trial court’s factual findings are “presumed correct and can be reversed only if they are not supported by competent substantial evidence, while the trial court’s legal conclusions are reviewed de novo.” Craven v. State, 285 So. 3d 992, 993 (Fla. 1st DCA 2019) (citing Mobley v. State, 132 So. 3d 1160, 1162 (Fla. 3d DCA 2014)). Pursuant to the Stand Your Ground
statute, the prosecution has the burden of proof by clear and convincing evidence to overcome the prima facie claim of self-defense: (4) In a criminal prosecution, once a prima facie claim of self-defense immunity from criminal prosecution has been raised by the defendant at a pretrial immunity hearing, the burden of proof by clear and convincing evidence is on the party seeking to overcome the immunity from criminal prosecution provided in subsection (1).
§ 776.032(4), Fla. Stat. (2017).
The trial court applied the current standard and correctly ruled that the State met its burden to show by clear and convincing evidence that the defendant was not entitled to immunity under the statute. The trial court set forth its findings of fact in the order denying immunity, appropriately ruling that clear and convincing evidence supported the legal conclusion that pre-trial immunity was inapplicable to the Petitioner’s facts. We find the record contains competent substantial evidence to deny immunity under the statute, and no legal error by the trial court in its application of the law. We therefore deny the petition for writ of prohibition.
Petition denied.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Love v. State, 247 So. 3d 609 (Fla. 3d DCA 2018)
- Mobley v. State, 132 So. 3d 1160 (Fla. 3d DCA 2014)
- Valdes v. State, 295 So. 3d 307 (Fla. 3d DCA 2021)
- Gainey v. State, 276 So. 3d 520 (Fla. 1st DCA 2020)