HOSEA MACK, APPELLANT,
v.
THE STATE OF FLORIDA, APPELLEE
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Hosea Mack appealed his conviction, challenging the admission of latent fingerprint evidence from a crime scene lifted two years prior without direct testimony from the detective who collected the prints. The Florida District Court of Appeal affirmed the conviction, holding that the trial court did not abuse its discretion in admitting the fingerprints based on sufficient authentication.
The trial court did not abuse its discretion in admitting the latent fingerprints into evidence because the state laid a sufficient predicate showing the fingerprint documents were what they purported to be, with no evidence of tampering or break in chain of custody. Direct authentication testimony from the original detective was not required.
[1] A trial court's evidentiary rulings are reviewed for abuse of discretion.
[2] The admission of evidence will not be disturbed on appeal absent a clear abuse of discretion.
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Join FLexlaw to unlock all legal intelligence“the latents were admissible because the State laid sufficient predicate to support a finding that the documents were, in fact, what they purported to be, and that there was no evidence of tampering or of any break in chain of custody.”
Establishes the standard for authentication of latent fingerprint evidence and the court's holding that the state satisfied it
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Join FLexlaw to unlock all legal intelligenceLatent fingerprints were taken from a crime scene and two years later presented at trial through the prosecution's expert fingerprint witness. The def…
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Hosea Mack seeks to reverse a final judgment and conviction. We affirm.
Mack seeks a new trial, arguing the trial court reversibly erred when it allowed the prosecution’s expert fingerprint witness to testify that certain latent fingerprints taken at a crime scene two years earlier matched the defendant’s fingerprints, without having authenticated the latents with the testimony of the police detective who actually lifted the prints at the crime scene. We review the trial court’s evidentiary rulings for abuse of *1012discretion. Roosevelt v. State, 42 So.3d 293, 297 (Fla. 3d DCA 2010) (holding that a trial court’s admission of evidence will not be disturbed on appeal absent a clear abuse of discretion); accord H & H Elec., Inc. v. Lopez, 967 So.2d 345, 347 (Fla. 3d DCA 2007). After reviewing the record, we conclude that the trial court did not abuse its discretion to allow the latent fingerprints into evidence.
The State did not rely solely on fingerprint evidence to establish guilt,1 and the latents were admissible because the State laid sufficient predicate to support a finding that the documents were, in fact, what they purported to be, and that there was no evidence of tampering or of any break in chain of custody.2 In determining whether the evidence submitted is sufficient for this purpose, the trial judge must evaluate each instance on its own merits, there being no specific list of requirements for such a determination. Unless clearly erroneous, the trial court’s determination will be sustained. The State’s showing was sufficient to establish that the latent fingerprint cards were what the State claimed them to be. See Daniels v. State, 634 So.2d 187, 192 (Fla. 3d DCA 1994) (citing Justus v. State, 438 So.2d 358, 365 (Fla.1983)).
Affirmed.
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Citator
Cited By
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Clark v. State, 268 So. 3d 751 (Fla. 4th DCA 2019)
Authorities Cited
- Coday v. State, 946 So. 2d 988 (Fla. 2006)
- Buddy Earl Justus v. State, 438 So. 2d 358 (Fla. 1983)
- Daniels v. State, 634 So. 2d 187 (Fla. 3d DCA 1994)
- H & H Elec., Inc. v. Lopez, 967 So. 2d 345 (Fla. 3d DCA 2007)
- Alton Roosevelt v. State, 42 So. 3d 293 (Fla. 3d DCA 2010)