TAYLOR M. EDWARDS
v.
STATE
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A conviction for leaving the scene of a crash under Florida law requires evidence that a vehicle collided with another vehicle, person, or object; a crash that did not involve such a collision is insufficient to support the conviction.
[1] A conviction for leaving the scene of a crash involving personal injury requires proof that a crash caused the alleged injury.
[2] The phrase "any vehicle involved in a crash" under section 316.027 requires that the vehicle collide with another vehicle, person, or object.
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Court's statement of the controlling legal standard from Gaulden v. State regarding the definition of 'crash' under section 316.027.
Edwards was convicted of leaving the scene of a crash involving personal injury. The State's evidence did not establish that a collision between a veh…
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PER CURIAM.
We reverse Taylor Edwards’ conviction for leaving the scene of a crash involving personal injury because the State’s evidence was insufficient to establish that a crash caused the injury alleged in the information.1 See Gaulden v. State, 195 So. 3d 1123, 1128 (Fla. 2016) (holding that section 316.027’s operative phrase “‘any vehicle involved in a crash’ means that vehicle must collide with another vehicle, person, or object”); see also Daugherty v. State, 207 So. 3d 980, 981 (Fla. 5th DCA 2016) (holding that crash that occurred when the victim, who was trying to climb in window of car, fell and collided with pavement, did not constitute crash under leaving scene of crash involving death statute).
We affirm, without discussion, Edwards’ other conviction.
AFFIRMED, in part; REVERSED, in part; and REMANDED.
EVANDER and EISNAUGLE, JJ., and ROGERS, S.G., Associate Judge, concur. 1 In his motion for judgment of acquittal at trial, Edwards failed to apprise the trial court as to why the State’s evidence was insufficient, as a matter of law, to support a conviction. Accordingly, our reversal is based on application of the fundamental error doctrine. See F.B. v. State, 852 So. 2d 226, 230 (Fla. 2003) (“[A]n argument that the evidence is totally insufficient as a matter of law to establish the commission of a crime need not be preserved. Such complete failure of the evidence meets the requirements of fundamental error . . . .”).
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Citator
Cited By
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Edwards v. State, 254 So. 3d 1195 (Fla. 5th DCA 2018)…*1196] Gaulden v. State , 195 So. 3d 1123, 1128 (Fla. 2016) (holding that section 316.027's operative phrase " 'any vehicle involved in a crash' means that vehicle must collide with another vehicle, person, or object"); see also Daugherty v. State , 207 So. 3d 980, 981 (Fla. 5th DCA 2016) (holding that crash that occurred when the victim, who was trying to climb in window of car, fell and collided with pavement, did not constitute crash under leaving scene of crash involving death statute). We affirm, without…
Authorities Cited
- F.B. v. State, 852 So. 2d 226 (Fla. 2003)
- Gaulden v. State, 195 So. 3d 1123 (Fla. 2016)
- Daugherty v. State, 207 So. 3d 980 (Fla. 5th DCA 2016)