ARMANDO VERDECIA
v.
STATE OF FLORIDA

Fla. 3d DCA | 2026-02-11
No. 2024-1273
2026 FL 1478 Florida District Court of Appeal, Third District (2026)

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Holding

A trial judge's response to a jury request without the prosecuting attorney, defendant, and defendant's counsel present and able to participate is per se reversible error, but this rule must be invoked by contemporaneous objection at trial.


Key Quotes

“it is prejudicial error for a trial judge to respond to a request from the jury without the prosecuting attorney, the defendant, and defendant's counsel being present and having the opportunity to participate in the discussion of the action to be taken on the jury's request.”

Ivory v. State, establishing the foundational rule requiring all parties' presence and participation in jury request responses.

Facts & Procedural History

Armando Verdecia appealed a trial court decision regarding jury procedures. The appeal involved the trial judge's handling of a jury request.…

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Opinion of the Court

PER CURIAM.

Affirmed. See Ivory v. State, 351 So. 2d 26 (Fla. 1977) (“We now hold that it is prejudicial error for a trial judge to respond to a request from the jury without the prosecuting attorney, the defendant, and defendant's counsel being present and having the opportunity to participate in the discussion of the action to be taken on the jury's request. This right to participate includes the right to place objections on record as well as the right to make full argument as to the reasons the jury's request should or should not be honored.") and Thomas v. State, 730 So. 2d 667 (Fla. 1998) (“The per se reversible error rule announced in Ivory is prophylactic in nature and must be invoked by contemporaneous objection at trial.").


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