TYLER D. PHILLIPS, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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Florida appellate court affirmed convictions for false imprisonment, sexual battery, and impersonating a police officer, finding evidentiary errors harmless and noting that restricting cross-examination about victim's probationary status was erroneous but did not affect the verdict.
Convictions for false imprisonment, sexual battery, and impersonating a police officer are affirmed because any evidentiary errors were harmless.
[1] Evidence of a witness's probationary status is admissible to show potential bias or motive, and trial court restriction of such cross-examination is erroneous even if har…
Previewing 1 of 1 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“Evidence of a witness's probationary status has probative value to show that the witness may have bias or motive.”
Court explaining that restricting cross-examination about victim's probationary status was erroneous because such evidence is probative of bias or motive.
Tyler D. Phillips was convicted of false imprisonment, sexual battery, and impersonating a police officer. The trial court restricted the defense from…
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BLUE, Acting Chief Judge.
Tyler D. Phillips appeals his convictions for false imprisonment, sexual battery and impersonating a police officer. He presents four evidentiary issues and one sentencing issue. The evidentiary issues are subject to a harmless error analysis. Applying that analysis, we conclude that these alleged errors did not affect the verdict. Additionally, Phillips’ issue regarding sexual predator status was resolved against him subsequent to the briefing in this case. See Collie v. State, 710 So. 2d 1000 (Fla. 2d DCA), review denied, 722 So. 2d 192 (Fla.), cert. denied, — U.S. -, 119 S.Ct. 624, 142 L.Ed.2d 563 (1998). Accordingly, we affirm.
Although harmless in this case, we write specifically to point out that the trial court’s ruling restricting the cross-examination of the victim was erroneous. The court prohibited the defense from asking the victim about her probationary status. Although it was unclear whether the victim knew she was on probation, that uncertainty went to the weight of the evidence, not to its admissibility. Evidence of a witness’s probationary status has probative value to show that the witness may have bias or motive. See Scott v. State, 730 So. 2d 732, 24 Fla. L. Weekly D603 (Fla. 2d DCA 1999).
Affirmed.
WHATLEY and CASANUEVA, JJ., Concur.
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Citator
Cited By
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Comesana v. State, 831 So. 2d 819 (Fla. 3d DCA 2002)…on the challenged evidentiary rulings to be invited and/or harmless. See Czubak v. State, 570 So. 2d 925, 928 (Fla.1990)(under invited error doctrine, party may not make or invite error and then take advantage of error on appeal); Phillips v. State, 739 So. 2d 632, 632 (Fla. 2d DCA 1999)(eviden-tiary issues were subject to harmless error analysis and not reversible when they did not affect the verdict).…
Authorities Cited
- Collie v. State, 710 So. 2d 1000 (Fla. 2d DCA 1998)
- Scott v. State, 730 So. 2d 732 (Fla. 2d DCA 1999)