SPILLERS
v.
STATE OF FLORIDA
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In this Anders review of a criminal conviction, the Florida First District Court of Appeal affirmed the trial court's judgment, finding no errors apparent on the face of the record. The court addressed and rejected potential appellate issues regarding a motion for judgment of acquittal and the imposition of fines.
The trial court properly denied the motion for judgment of acquittal because a jury could lawfully find the appellant guilty based on the evidence presented. The trial court also did not err in imposing fines, as the record does not show the court delegated its discretionary authority to determine the fines to the clerk.
[1] An appellate court must examine the record to discover any errors apparent on its face when reviewing an Anders brief.
[2] A denial of a motion for judgment of acquittal is reviewed de novo, viewing the evidence in a light most favorable to the State.
Previewing 2 of 5 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“A trial court cannot grant judgment of acquittal 'unless the evidence is such that no view which the jury may lawfully take of it favorable to the opposite party can be sustained under the law.'”
Establishes the legal standard for reviewing a trial court's denial of a motion for judgment of acquittal, requiring that evidence be viewed in the light most favorable to the prosecution.
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Join FLexlaw to unlock all legal intelligenceA jury found the appellant guilty of criminal charges based on testimony from the victim and corroborating witnesses. The victim's testimony was consi…
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PER CURIAM.
Appellate counsel filed a brief pursuant to Anders v. California, 386 U.S. 738 (1967). This Court conducted its required review. State v. Causey, 503 So. 2d 321, 322 (Fla. 1987) (an appellate court “must examine the record to the extent necessary to discover any errors apparent on the face of the record.”). We found no errors apparent on the face of the record and affirm. But we write to address what appellate counsel flagged as potential issues for our review.
First, the trial court properly denied the motion for judgment of acquittal. This Court reviews a denial of a judgment of acquittal de novo and must view the evidence in a light most favorable to the State. Robinson v. State, 327 So. 3d 903, 904 (Fla. 1st DCA
2021). “A trial court cannot grant judgment of acquittal ‘unless the evidence is such that no view which the jury may lawfully take of it favorable to the opposite party can be sustained under the law.’” Id. (quoting Lynch v. State, 293 So. 2d 44, 45 (Fla. 1974)). Here, a jury could lawfully find Appellant guilty. The victim’s testimony, which was consistent with her prior statements, detailed Appellant’s criminal acts, and other witnesses corroborated the story. See Gosciminski v. State, 132 So. 3d 678, 710–11 (Fla. 2013) (finding the evidence sufficient for purposes of reviewing a ruling on a motion for judgment of acquittal).
Second, the trial court did not err when it imposed fines. Appellant argues on appeal that the court improperly delegated its authority to the clerk. Yet Appellant fails to show that the court delegated its discretionary authority. On the record, the court asked the clerk to report the fines—the record does not show that the court ever asked the clerk to determine the fines. The face of the record therefore does not reveal this issue to be nonfrivolous for appeal.
Appellant’s cited case, Cromartie v. State, does not support his proposition. 70 So. 3d 559 (Fla. 2011). In Cromartie, the Florida Supreme Court determined that the trial court committed fundamental error by extending the defendant’s sentence merely for reasons of “rounding up” (from 7.83 years’ imprisonment to 8 years). Id. at 564. Here, the record does not indicate that the trial court imposed its sentence based on “rounding up” or anything similar. Because the face of the record does not reveal any nonfrivolous issues for appeal, we affirm.
AFFIRMED.
ROWE, NORDBY, and LONG, JJ., concur. _____________________________
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Citator
Authorities Cited
- Anders v. California, 386 U.S. 738 (U.S. 1967)
- State v. Causey, 503 So. 2d 321 (Fla. 1987)
- Lynch v. State, 293 So. 2d 44 (Fla. 1974)
- Gosciminski v. State, 132 So. 3d 678 (Fla. 2013)
- Cromartie v. State, 70 So. 3d 559 (Fla. 2011)