LAWRENCE VINCENT CHAMBERS, APPELLANT,
v.
THE STATE OF FLORIDA, APPELLEE
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Lawrence Vincent Chambers was convicted of burglary with assault/battery of an occupied dwelling while armed and armed robbery. The Florida District Court of Appeal reversed and remanded for a new trial because the trial court committed reversible error by admitting out-of-court accusations and character evidence, and the state failed to prove harmlessness beyond a reasonable doubt given equivocal victim and accomplice testimony.
The trial court committed error in admitting the out-of-court accusatory statements and character evidence regarding the robbery clearing house, which violated Florida law. The state failed to meet its burden of demonstrating harmlessness because the victim's identification was equivocal (she initially described a different physical characteristic) and the accomplice-witness admitted lying to protect another suspect.
[1] Out-of-court accusatory statements are inadmissible to establish the logical sequence of events and cannot be argued as proof of guilt.
[2] Evidence that an investigating detective contacted a "robbery clearing house" to exchange information about a defendant is inadmissible character evidence, presumptively…
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Join FLexlaw to unlock all legal intelligence“the trial court erred when it repeatedly permitted the state to elicit out-of-court statements relating accusatory information, to establish the logical sequence of events...and to thereafter argue this inadmissible testimony as proof of his guilt”
Establishes the primary error of admitting inadmissible accusatory hearsay
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Join FLexlaw to unlock all legal intelligenceChambers was tried for burglary with assault/battery of an occupied dwelling while armed and armed robbery. The victim identified Chambers as the perp…
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[*840] PER CURIAM.
Lawrence Vincent CHambers appeals his convictions and sentences for burglary with an assault or battery of an occupied dwelling while armed and armed robbery, following a jury trial. For the reasons that follow, we reverse and remand for a new trial.
Chambers first asserts, and we agree, that the trial court erred when it repeatedly permitted the state to elicit out-of-court statements relating accusatory information, to establish the logical sequence of events, see Conley v. State, 620 So. 2d 180, 182-83 (Fla.1993), and to thereafter argue this inadmissible testimony as proof of his guilt. See Trotman v. State, 652 So. 2d 506, 507 (Fla. 3d DCA 1995); Davis v. State, 493 So. 2d 11, 12-13 (Fla. 3d DCA 1986); Molina v. State 406 So. 2d 57, 57-58 (Fla. 3d DCA 1981); Postell v. State, 398 So. 2d 851, 854 (Fla. 3d DCA 1981). We also agree that the trial court further erred when it permitted the state’s detective witness to state that as part of his investigation of this case, he contacted the “robbery clearing house” for the purpose of sharing or exchanging information about Chambers with other police departments. The only obvious relevancy of such evidence was to attack Chambers’ character and to demonstrate his possible involvement in other uncharged robberies which is violative of section 90.404, Florida Statutes (1997), and presumptively harmful. See Gore v. State, 719 So. 2d 1197, 1199 (Fla.1998); Czubak v. State, 570 So. 2d 925, 928 (Fla.1990).
Given these errors, we must now determine whether the state, as the beneficiary of the same, has met its burden under State v. DiGuilio, 491 So. 2d 1129, 1135 (Fla.1986), of demonstrating the harmlessness of these errors. We conclude that it has not. The state’s only admissible evidence of Chambers’ involvement in these crimes consisted of the testimony given by the victim and a co-defendant, David Callahan, who later became a witness for the state in exchange for a lenient sentence. Although the victim identified Chambers, at trial, as the man who had robbed her at gunpoint, she had initially told the police that the perpetrator had a crooked nose. Chambers does not have a crooked nose, but the evidence revealed that another uncharged co-perpetrator in this crime known as “Jay” or “Brown” does have a crooked nose. Callahan likewise testified as to Chambers’ involvement in the crimes charged, but he also admitted that he had lied to the police in order to protect “Jay” or “Brown,” or the uncharged co-perpetrator with the crooked nose. Given such equivocal evidence of Chambers’ culpability for the crimes charged, we do not believe that it can be concluded that there is no reasonable possibility that the errors committed in this trial were harmless and did not contribute to the jury’s verdict. See DiGuilio, 491 So. 2d at 1135. For that reason, we reverse the convictions and sentences and remand for a new trial.
Reversed.
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Miller v. State, 804 So. 2d 609 (Fla. 3d DCA 2002)…at trial.1 This evidence of similar crimes was brought in, as demonstrated by the prosecutor’s insistence and emphasis, to show defendant’s propensity to commit crimes. The court abused its discretion in permitting this evidence. Chambers v. State, 742 So. 2d 839, 840 (Fla. 3d DCA 1999); Adams v. State, 743 So. 2d 1216, 1217 (Fla. 4th DCA 1999). The state asserts that this questioning was an appropriate response to the defense’s attempts to cloud the issue of Miller’s previous convictions. This argument is…
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Carbonell v. State, 47 So. 3d 944 (Fla. 3d DCA 2010)…s, to be allowed to introduce evidence of another crime, the State must establish that the uncharged crime is relevant to some issue that is in dispute and is not being introduced to establish propensi [*947] ty to commit a crime. Chambers v. State, 742 So. 2d 839, 840 (Fla. 3d DCA 1999). Before admitting Williams Rule evidence, the trial court must make four determinations: whether there is sufficient evidence that the defendant committed the uncharged crime; whether the evidence in the uncharged crime meets…
Authorities Cited
- State v. DiGUILIO, 491 So. 2d 1129 (Fla. 1986)
- Czubak v. State, 570 So. 2d 925 (Fla. 1990)
- Gore v. State, 719 So. 2d 1197 (Fla. 1998)
- Postell v. State, 398 So. 2d 851 (Fla. 3d DCA 1981)
- Conley v. State, 620 So. 2d 180 (Fla. 1993)
- Molina v. State, 406 So. 2d 57 (Fla. 3d DCA 1981)
- Davis v. State, 493 So. 2d 11 (Fla. 3d DCA 1986)
- Martin v. State, 652 So. 2d 506 (Fla. 4th DCA 1995)
- Trotman v. State, 652 So. 2d 506 (Fla. 3d DCA 1995)