STATE OF FLORIDA, PETITIONER,
v.
YUL MEDINA, RESPONDENT
AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.
The State sought certiorari review of a trial court order requiring disclosure of a confidential informant's identity. The appellate court held that the trial court departed from essential legal requirements by failing to conduct an in camera hearing before ordering disclosure, even though the defendant had established a prima facie case for disclosure.
Yes. When a defendant meets the initial burden of showing that disclosure is necessary to a specific defense, the trial court is obligated to hold an in camera hearing to determine whether disclosure would be relevant and helpful to that defense before ordering disclosure.
[1] A trial court must conduct an in camera hearing before ordering the disclosure of a confidential informant's identity when the defendant demonstrates that the informant's…
[2] Disclosure of a confidential informant's identity is required if the informant's identity or the content of their communication is relevant and helpful to the defense of…
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“Disclosure of a confidential informant is required if an informant's identity or content of his communication is relevant and helpful to the defense of an accused or is essential to a fair determination of a cause.”
Establishes the two-part test for when confidential informant disclosure is required under Florida law.
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceRespondent Medina moved to disclose the identity of a confidential informant, asserting a potential entrapment defense. The trial court granted the mo…
The full statement of facts, procedural history, and disposition for this case are member content.
Join FLexlaw to unlock all legal intelligence© FLexlaw, Inc. — AI-generated enrichments are proprietary. All rights reserved.
Explore caselaw by topic → Browse Due Process Considerations cases and more on FLexlaw
The State seeks certiorari relief with respect to the trial court’s order granting respondent’s motion to disclose the identity of a confidential informant. We grant the petition. We agree that the trial court departed from the essential requirements of law when it declined to conduct an in camera hearing before it ordered the disclosure. State v. Titus, 70 So.3d 763 (Fla. 4th DCA 2011); State v. Rivas, 25 So.3d 647, 650 (Fla. 4th DCA 2010); Thomas v. State, 28 So.3d 240 (Fla. 4th DCA 2010); Miller v. State, 729 So.2d 417, 419-20 (Fla. 4th DCA 1999); State v. Ayala, 713 So.2d 1050, 1052 (Fla. 3d DCA 1998); State v. Roberts, 686 So.2d 722, 723 (Fla. 2d DCA 1997).
As this court and others have explained: Disclosure of a confidential informant is required if an informant’s identity or content of his communication is relevant and helpful to the defense of an accused or is essential to a fair determination of a cause. The first component necessarily centers around a specific defense asserted by the defendant in the case, as to which the informant’s testimony is material and helpful. See State v. Zamora, 534 So.2d [864,] 868 [ (Fla. 3d DCA 1988)]. The second component concentrates on general due process considerations and is not confined to a defense raised by the defendant.
State v. LaBron, 24 So.3d 715, 717 (Fla. 4th DCA 2009) (quoting Miller, 729 So.2d at 419); see also Roviaro v. United States, 353 U.S. 53, 60-61, 77 S.Ct. 623, 1 L.Ed.2d 639 (1957). When a defendant succeeds in meeting the “initial burden of showing that disclosure is necessary to a specific defense, the trial court should hold an in camera hearing to determine, in fact, whether the disclosure would be relevant and helpful to the defense.” LaBron, 24 So.3d at 717 (quoting Roberts, 686 So.2d at 723); see also Zamora, 534 So.2d at 869 (explaining that in camera review has been confined exclusively to the first alternative component of the Roviaro exception).
Here, the trial court determined that respondent met his burden with respect to the first component, setting forth a potential entrapment defense, and that the second component did not apply. The State’s sole argument in this petition is that the in camera hearing is required. As outlined, the trial court was obligated to conduct the hearing. Rivas, 25 So.3d at 651; Titus, 70 So.3d at 764; State v. Burgos, 985 So.2d 642 (Fla. 2d DCA 2008). Accordingly, the order on review is quashed, and the case is remanded for further proceedings consistent with this opinion.
Petition granted.
TAYLOR, CONNER and FORST, JJ., concur.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Roviaro v. United States, 353 U.S. 53 (U.S. 1957)
- State v. Roberts, 686 So. 2d 722 (Fla. 2d DCA 1997)
- Koslovsky Realty, Inc. v. Losek, 729 So. 2d 417 (Fla. 3d DCA 1999)
- Moody v. State, 713 So. 2d 1050 (Fla. 5th DCA 1998)
- State v. LaBRON, 24 So. 3d 715 (Fla. 4th DCA 2009)
- State v. Burgos, 985 So. 2d 642 (Fla. 2d DCA 2008)
- Roker v. State, 25 So. 3d 647 (Fla. 4th DCA 2010)
- Thomas v. State, 28 So. 3d 240 (Fla. 4th DCA 2010)
- State v. Leonicio Rivas and Juan Rodriguez-Abrea, 25 So. 3d 647 (Fla. 4th DCA 2010)
- State v. Subi Titus, 70 So. 3d 763 (Fla. 4th DCA 2011)