THE STATE OF FLORIDA, APPELLANT,
v.
ALDWYN POWELL, APPELLEE

Fla. 3d DCA | 1990-09-11
No. 90-372
Before SCHWARTZ, C.J., JORGENSON and GODERICH, JJ.
566 So. 2d 588 Florida District Court of Appeal, Third District (1990) Positive Treatment
Cited by 8 cases


Opinion of the Court
PER CURIAM.

PER CURIAM.

The State of Florida appeals from an order of dismissal for failure to comply with discovery requests.

Dismissal of criminal charges is too excessive a sanction for the State’s failure to comply with discovery requests where, as here, “the defendant was not significantly prejudiced by the State’s failure to produce the requested evidence,” and where the speedy trial period had not yet run. State v. Del Gaudio, 445 So. 2d 605, 611 (Fla. 3d DCA), rev. denied, 453 So. 2d 45 (Fla.1984). See also, State v. Brown, 527 So. 2d 209 (Fla. 3d DCA) (defendant not entitled to dismissal where alleged discovery violation did not adversely affect ability to prepare for trial and information sought would not have been helpful to defense), rev. denied, 534 So. 2d 398 (Fla.1988). Accordingly, the order of dismissal is reversed and the cause is remanded for further proceedings consistent with this opinion.

Reversed and remanded.


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  • Flavia Alvarez v. State Farm Mut. Auto Ins. Co., 635 So. 2d 131 (Fla. 3d DCA 1994)
    …nt’s motion below, however, established uncontra-dictedly that Alvarez was not living at that address on the date of service or for some time before. See Hunt Exterminating Co. v. Crum, 598 So. 2d 113 (Fla. 2d DCA 1992); Partrade, Inc. v. Marchiano, 566 So. 2d 588 (Fla. 3d DCA 1990); Marshall Davis, Inc. v. Incapco, Inc., 558 So. 2d 206 (Fla. 2d DCA 1990). It is therefore apparent that the purported service of process was ineffective as a matter of law, see Kennedy v. Richmond, 512 So. 2d 1129 (Fla. 4th DCA 1…
  • Delgado v. State, 890 So. 2d 1269 (Fla. 5th DCA 2005)
    …r failure of timely disclosure is a “severe sanction,” that “should be a last resort reserved for extreme or aggravated circumstances.” Livigni v. State, 725 So. 2d 1150, 1151 (Fla. 2d DCA 1998); see also Tomengo, 864 So. 2d at 529; State v. Powell, 566 So. 2d 588 (Fla. 3d DCA 1990). Certainly, less draconian measures were available in the present case. More importantly, a trial court is absolutely required to conduct a Richardson hearing before imposing any sanction, let alone excluding a witness. See Smith…
  • Godwin v. State, 580 So. 2d 176 (Fla. 1st DCA 1991)
    …forward with the trial despite the trial court’s statement that it would grant a continuance and would probably set trial for July 9th, appellant failed to establish irreparable prejudice resulting from the discovery violation. See State v. Powell, 566 So. 2d 588 (Fla. 3d DCA 1990). Affirmed. SMITH and WIGGINTON, JJ., concur. . Section 817.563, Florida Statutes, provides in part: 817.563 Controlled substance named or described in s. 893.03; sale of substance in lieu thereof. — It is unlawful for any pers…

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