NATHANIEL WILLIAMS, PETITIONER,
v.
STATE OF FLORIDA, RESPONDENT
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The Florida Supreme Court quashed and remanded the Third District Court of Appeal's decision because that court applied an incorrect harmless error standard in reviewing a trial court error in Williams's criminal conviction. The Supreme Court reaffirmed that appellate courts must apply the DiGuilio standard, which requires the state to show beyond a reasonable doubt that an error did not affect the verdict.
The correct harmless error standard is that set forth in DiGuilio: the burden is on the state to show beyond a reasonable doubt that an error did not affect the verdict, and the focus is on whether there is a reasonable possibility the error affected the verdict. The Third District's application of a different standard—considering whether the error 'necessarily deprived' Williams of a fair trial based on other evidence—departed from the required DiGuilio standard.
[1] An appellate court must determine whether there is a reasonable possibility that an error affected the verdict when applying the harmless error standard.
[2] The burden to demonstrate that a trial error was harmless rests with the State.
Previewing 2 of 5 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“The focus is on the effect of the error on the trier-of-fact. The question is whether there is a reasonable possibility that the error affected the verdict. The burden to show the error was harmless must remain on the state. If the appellate court cannot say beyond a reasonable doubt that the error did not affect the verdict, then the error is by definition harmful.”
Establishes the governing harmless error standard that appellate courts must apply
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Join FLexlaw to unlock all legal intelligenceNathaniel Williams was convicted at trial. The trial court committed a preserved error during the proceedings. The Third District Court of Appeal uphe…
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PARIENTE, J.
We have for review the Third District Court of Appeal’s decision in Williams v. State, 834 So. 2d 923 (Fla. 3d DCA 2003), which expressly and directly conflicts with our decisions in Goodwin v. State, 751 So. 2d 537 (Fla.1999), and State v. DiGui-lio, 491 So. 2d 1129 (Fla.1986), on the harmless error standard of review. We have jurisdiction. See art. V, § 3(b)(3), Fla. Const. In DiGuilio, this Court set out the test to be applied in determining whether an error is harmful:
The test is not a sufficiency-of-the-evidence, a correct result, a not clearly wrong, a substantial evidence, a more probable than not, a clear and convine- ing, or even an overwhelming evidence test. Harmless error is not a device for the appellate court to substitute itself for the trier-of-fact by simply weighing . the evidence. The focus is on the effect of the error on the trier-of-fact. The question is whether there is a reasonable possibility that the error affected the verdict. The burden to show the error was harmless must remain on the state. If the appellate court cannot say beyond a reasonable doubt that the error did not affect the verdict, then the error is by definition harmful.
491 So. 2d at 1139. We reaffirmed this harmless error standard in Goodwin, holding that the enactment of section 924.051(7), Florida Statutes (Supp.1996), did not alter the obligation of the appellate courts to independently review both constitutional and nonconstitutional errors for harmlessness under the DiGuilio standard. See Goodwin, 751 So. 2d at 542-43.
In this ease, the Third District departed from the DiGuilio standard in holding that a preserved trial court error did not warrant reversal because “given all of the other evidence as to William’s [sic] guilt, we cannot conclude that this error necessarily deprived Williams of a fair trial.” Williams, 834 So. 2d at 925 (emphasis supplied). We recently quashed and remanded for reconsideration a decision of the Second District Court of Appeal in which that court used an incorrect harmless error test. See Knowles v. State, 848 So. 2d 1055, 1058-59 (Fla.2003). Consistent with Knowles, as well as with our decisions in DiGuilio and Goodwin, we quash in part the Third District’s decision in this case and remand for reconsideration under the correct harmless error standard. We decline to address the additional issue raised by Williams that is beyond the scope of the conflict issue. See Asbell v. State, 715 So. 2d 258, 258 (Fla.1998).
It is so ordered.
ANSTEAD, C.J., and LEWIS, QUINCE, and CANTERO, JJ., concur. BELL, J., concurs in result only.
WELLS, J., dissents with an opinion.
WELLS, J.,
dissenting.
I would discharge jurisdiction. I believe the majority gives to the Third District’s opinion tod cramped a reading. I do not read the opinion to conflict with State v. DiGuilio, 491 So. 2d 1129 (Fla.1986). The Third District’s decision as to the merits is correct.
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Citator
Cited By (17 total)
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Scipio v. State, 928 So. 2d 1138 (Fla. 2006)…ecision in Scipio v. State, 867 So. 2d 427 (Fla. 5th DCA 2004), on the basis of conflict with numerous prior decisions of other district courts and this Court, including the decisions in Pender v. State, 700 So. 2d 664 (Fla.1997); Williams v. State, 863 So. 2d 1189 (Fla.2003); and State v. Schopp, 653 So. 2d 1016 (Fla.1995). This Court has jurisdiction pursuant to article V, section 3(b)(3) of the Florida Constitution. Because we find the State has not demonstrated the harmlessness of a discovery violation, we…1 / 2
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Aundra Johnson v. State, 53 So. 3d 1003 (Fla. 2010)…helming evidence.” As recently em [*1006] phasized by this Court in Ventura v. State, 29 So. 3d 1086, 1089 (Fla.2010), an "overwhelming evidence” test is not the correct test for determining whether an error was harmless. See also Williams v. State, 863 So. 2d 1189, 1189-90 (Fla.2003). . We note, however, that if a jury requests a specific read-back, a trial judge has broad discretion in deciding whether to grant the jury’s request. State v. Riechmann, 777 So. 2d 342, 365 (Fla.2000). Refusing a jury's specifi…
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Gregory v. State, 118 So. 3d 770 (Fla. 2013)…of this testimony was harmless beyond a reasonable doubt. See State v. DiGuilio, 491 So. 2d 1129, 1139 (Fla.1986). In determining whether an error was harmful, the focus is on the effect that the error has upon the trier-of-fact. Williams v. State, 863 So. 2d 1189, 1190 (Fla.2003). In other words, “[t]he question is whether there is a reasonable possibility that the error affected the verdict.” Id. (quoting DiGuilio, 491 So. 2d at 1139). “If the appellate court cannot say beyond a reasonable doubt that the er…
Previewing 3 of 17 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- State v. DiGUILIO, 491 So. 2d 1129 (Fla. 1986)
- Goodwin v. State, 751 So. 2d 537 (Fla. 1999)
- Knowles v. State, 848 So. 2d 1055 (Fla. 2003)
- Asbell v. State, 715 So. 2d 258 (Fla. 1998)
- Williams v. State, 834 So. 2d 923 (Fla. 3d DCA 2003)