THE STATE OF FLORIDA, PETITIONER,
v.
VINCENT LAMONT MEEKS, RESPONDENT
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The State of Florida sought to quash a trial court order requiring disclosure of grand jury testimony in a capital murder case. The appellate court held that a defendant's motion for disclosure based merely on speculation, without factual support, does not satisfy the legal standard for breaching grand jury confidentiality.
A defendant's motion for disclosure of grand jury testimony must be based on more than mere surmise or speculation; it must contain actual facts supporting the claim that disclosure is essential to justice. The trial court's order requiring disclosure based on the defendant's unsupported allegations departed from the essential requirements of law and was properly quashed.
[1] Grand jury testimony is confidential and may only be disclosed when required by a court to further justice.
[2] A court may relax the rule of grand jury secrecy when disclosure is essential to the attainment of justice and the vindication of truth.
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Join FLexlaw to unlock all legal intelligence“any ... person appearing before the grand jury shall not disclose the testimony of a witness examined before the grand jury or other evidence received by it except when required by a court to disclose the testimony for the purpose of: (c) Furthering justice.”
Establishes the statutory framework governing grand jury secrecy and the exceptions allowing disclosure
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Join FLexlaw to unlock all legal intelligenceVincent Lamont Meeks was indicted for one count of first degree murder and two counts of attempted second degree murder. Meeks filed a motion seeking …
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PER CURIAM.
The State of Florida seeks a writ of certiorari quashing the trial court’s order requiring the disclosure of grand jury testimony. We grant the petition and quash the order under review.
The respondent, Vincent Lamont Meeks, was indicted by the Dade County Grand Jury and charged with one count of first degree murder and two counts of attempted second degree murder. The respondent filed a motion seeking the disclosure of the lead detective’s grand jury testimony. The motion alleged that he was entitled to question the lead detective about her grand jury testimony because he was investigating whether the State failed to inform the grand jury about certain facts. The State responded that the respondent had made no showing of any sufficient interest or reason to breach the policy of confidentiality of grand jury proceedings. Thereafter, the trial court granted the respondent’s motion and ordered that the lead detective disclose her grand jury testimony for the purpose of furthering justice.
Section 905.27, Florida Statutes (1991), provides in part as follows:
(1) [A]ny ... person appearing before the grand jury shall not disclose the testimony of a witness examined before the grand jury or other evidence received by it except when required by a court to disclose the testimony for the purpose of:
(c) Furthering justice. We acknowledged that when disclosure becomes essential to the attainment of justice and the vindication of the truth, the rule of secrecy may be relaxed in the discretion of the court.” Minton v. State, 113 So. 2d 361, 365 (Fla.1959). However, mere surmise or speculation is not a proper predicate for securing access to grand jury testimony. See Jent v. State, 408 So. 2d 1024 (Fla.1981); Minton.
In the instant case, the respondent’s motion seeking disclosure did not contain any facts which supported his allegations that the State had withheld critical facts from the grand jury. Thus, we find that the respondent’s motion was based on “mere surmise or speculation.” For this reason, we find that the trial court’s order was a departure from the essential requirements of the law. Accordingly, we quash the order under review.
Certiorari granted; order quashed.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By
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State v. Reese, 670 So. 2d 174 (Fla. 4th DCA 1996)…1995) (granting cer-tiorari and quashing order that required disclosure of grand jury testimony because defendant failed to make strong showing of particularized need as required for disclosure of grand jury minutes or witness list); State v. Meeks, 610 So. 2d 647 (Fla. 3rd DCA 1992) (granting certiorari and quashing an order requiring disclosure of grand jury testimony as the defendant’s motion seeking disclosure was based on mere surmise or speculation). At bar, there is no indication from the trial court’…
Authorities Cited
- Jent v. State, 408 So. 2d 1024 (Fla. 1981)
- Minton v. State, 113 So. 2d 361 (Fla. 1959)