BRUCE NIVEN BROCK, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE

Fla. 1st DCA | 2012-11-16
No. 1D11-6756
Benton, C.J., Davis, J., Roberts, J.
100 So. 3d 292 Florida District Court of Appeal, First District (2012)

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Synopsis

The court reversed Brock's conviction for possession of a firearm by a convicted felon because the trial court erroneously admitted evidence of a second firearm unrelated to the charged crime, creating a reasonable possibility of prejudicial impact on the jury.


Holding

Evidence of a firearm unrelated to the charged crime must be excluded because irrelevant collateral crimes evidence is presumed harmful and creates a reasonable possibility of contributing to conviction.


Headnotes

[1] Irrelevant collateral crimes evidence is presumed harmful and may not be admitted when it creates a reasonable possibility of contributing to a conviction for an unrelate…

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Key Quotes

“Irrelevant collateral crimes evidence is presumed harmful because of the danger that a jury will interpret it as evidence of guilt.”

Court explaining the legal standard for admitting collateral crimes evidence and why the second firearm was prejudicial.

Facts & Procedural History

Brock was charged with possession of a firearm by a convicted felon. The trial court admitted two firearms found in his residence, but only one was li…

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Opinion of the Court
PER CURIAM.

PER CURIAM.

Appellant, Bruce Niven Brock, challenges his conviction and sentence for possession of a firearm by a convicted felon. Appellant argues and, the State concedes, that the trial court erred in admitting evidence of a firearm that was unrelated to the charged crime.

The trial court allowed the State to introduce two firearms that were located within Appellant’s residence. However, the State only presented testimony that linked one of the firearms (State’s Exhibit 11) to the charged crime. There was no testimony or other evidence to show that Appellant actually possessed the second firearm (State’s Exhibit 12). Irrelevant collateral crimes evidence is presumed harmful because of the danger that a jury will interpret it as evidence of guilt. Agatheas v. State, 77 So.3d 1282, 1240 (Fla.2011). Because there is a reasonable possibility that the jury could have viewed the erroneously admitted evidence (State’s Exhibit 12) as showing Appellant’s bad character or propensity to possess firearms and a reasonable possibility that the evidence of the second firearm could have contributed to Appellant’s conviction, we reverse Appellant’s conviction and remand for a new trial.

REVERSED and REMANDED.

BENTON, C.J., DAVIS and ROBERTS, JJ., concur.


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