STATE OF FLORIDA, PETITIONER,
v.
WOODROW E. MEDLIN, RESPONDENT
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Florida appellate court vacated trial court's order compelling disclosure of a confidential informant's identity, holding that the trial court must conduct an in camera hearing to balance the defendant's entrapment defense needs against the state's interest in protecting the informer before ordering disclosure.
A trial court must conduct an in camera hearing to determine whether an informant's identity must be disclosed to a defendant claiming entrapment, balancing the defendant's fair trial rights against the state's interest in protecting the informer.
[1] A trial court must conduct an in camera hearing to determine whether disclosure of a confidential informant's identity is necessary for a defendant's entrapment defense,…
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Join FLexlaw to unlock all legal intelligenceThe defendant moved to compel disclosure of a confidential informant's identity, claiming the information was necessary for his entrapment defense.…
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PER CURIAM.
The state petitions for the issuance of a writ of certiorari to vacate an order that granted the defendant’s motion to compel disclosure of a confidential informant. We have jurisdiction. See State v. Pettis, 520 So. 2d 250 (Fla.1988); State v. Hernandez, 546 So. 2d 761 (Fla. 2d DCA 1989).
In accordance with the principles enunciated in the factually similar case of Munford v. State, 343 So. 2d 67 (Fla. 2d DCA 1977), quashed on other grounds, 357 So. 2d 706 (Fla.1978), we hold that the defendant made a sufficient initial showing to suggest that nondisclosure of the informant’s identity would hinder the preparation of his entrapment defense. The record, however, does not conclusively demonstrate that the defendant’s right to a fair trial outweighs the state’s interest in protecting the identity of the informer. Munford, 343 So. 2d at 69. As such, we further hold that the trial court departed from the essential requirements of the law in granting the motion to compel disclosure without first conducting an in camera hearing to determine whether the informant's testimony might be helpful to the defendant.
Accordingly, we grant the petition, issue the writ, and remand the matter to the trial court with directions to vacate the order compelling disclosure of the informant's identity and for further proceedings in compliance with Munford.
RYDER, A.C.J., and DANAHY and PARKER, JJ., concur.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- State v. Pettis, 520 So. 2d 250 (Fla. 1988)
- State v. Munford, 357 So. 2d 706 (Fla. 1978)
- Munford v. State, 343 So. 2d 67 (Fla. 2d DCA 1977)
- State v. Hernandez, 546 So. 2d 761 (Fla. 2d DCA 1989)