SHERICKA WILLIAMS, APPELLANT,
v.
THE STATE OF FLORIDA, APPELLEE
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Florida appellate court held that the statutory accident privilege excluding crash-report statements from evidence does not protect a defendant who fled the scene of a fatal accident, affirming her conviction for leaving the scene.
The accident privilege in section 316.066(4) does not apply to a person who abandons the duty to remain at the scene of a fatal automobile accident.
[1] The statutory accident privilege excluding crash-report statements from evidence under section 316.066(4) does not apply to a person who violates the duty to remain at th…
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Join FLexlaw to unlock all legal intelligenceShericka Williams fled the scene of an automobile crash that resulted in death and made statements to law enforcement about the crash.…
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The issue in this case is whether section 316.066(4) of the Florida Statutes (2012), which excludes from evidence in any civil or criminal trial statements made by a “person involved in an [automobile] crash ... to a law enforcement officer for the *197purpose of completing a crash report[,]” confers any benefit on Shericka Williams, the appellant in this case, who fled the scene of an automobile crash that resulted in death. For the reasons discussed in State v. Ferguson, 405 So.2d 294 (Fla. 4th DCA 1981) and Cummings v. State, 780 So.2d 149 (Fla. 2d DCA 2001), which we acknowledge treated earlier versions of the same statutory scheme, we hold that the accident privilege in section 316.066(4) does not confer any benefit or privilege on a person who abandons her duty to remain at the scene of any automobile accident which results in death, and who chooses instead to leave the scene of an accident, contrary to section 316.027(l)(b) of the Florida Statutes (2013).
For this reason, we approve the decision of the trial court which correctly denied Williams’ dispositive motion to dismiss the statements made by her concerning the automobile crash in this case after she fled from the scene, and affirm the conviction and sentence for fleeing the scene of an accident.
Affirmed.
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Citator
Cited By
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Juarez v. Crews (M.D. Fla. 2024)…about one hundred feet from his car. (Respondent's Exhibit 3 at 11-14) The trial court denied Juarez's motion to suppress his statements to Trooper Yock during the traffic investigation because Juarez left the scene of the crash. Williams v. State, 208 So. 3d 196, 197 (Fla. 3d DCA 2016) (“[T]he accident privilege in section 316.066(4) does not confer any benefit or privilege on a person who abandons her duty to remain at the scene of any automobile accident which results in death, and who chooses instead to…
Authorities Cited
- State v. Ferguson, 405 So. 2d 294 (Fla. 4th DCA 1981)
- Octavious Cummings v. State, 780 So. 2d 149 (Fla. 2d DCA 2000)