KYLE FALES
v.
STATE OF FLORIDA
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The Florida First District Court of Appeal reversed and remanded a trial court's denial of a motion for new trial, finding that the trial court applied the wrong legal standard when evaluating the motion. The court held that trial courts must weigh the evidence and determine which side's evidence is more credible when ruling on motions for new trial, not merely assess the sufficiency of the evidence.
The trial court erred by applying the sufficiency-of-the-evidence standard to the weight-of-the-evidence arguments in the motion for new trial. When ruling on such motions, trial courts must evaluate the weight of the evidence and determine which side has the greater amount of credible evidence supporting its position.
[1] When a trial court rules on a motion for new trial based on weight of the evidence, the court must evaluate the credibility of the evidence and determine whether a greate…
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Court explaining the correct standard for ruling on motions for new trial, citing Jordan v. State
The appellant filed a motion for new trial raising both sufficiency-of-the-evidence and weight-of-the-evidence arguments. The trial court denied the m…
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the weight of the evidence and to act, in effect, as an additional juror.” Jordan v. State, 244 So. 3d 1178, 1179 (Fla. 1st DCA 2018); see also Tibbs v. State, 397 So. 2d 1120, 1123 (Fla. 1981) (explaining that, when ruling on a motion for new trial, the trial court is required to evaluate the weight of the evidence and determine whether “a greater amount of credible evidence supports one side of an issue or cause than the other”).
This conclusion is not undercut by our recent decisions in Bell v. State, 248 So. 3d 208 (Fla. 1st DCA 2018), and Moreland v. State, 253 So. 3d 1245 (Fla. 1st DCA 2018), because those cases are distinguishable. There was no indication that the trial courts in those cases used the wrong standard when ruling on the defendants’ motions for new trial because the courts essentially denied the motions without explanation. See Bell, 248 So. 3d at 210 (“Bell raised both sufficiency-of-the-evidence and weight-of-the-evidence arguments in his new-trial motions. While the judges’ oral rulings only addressed the standard for the sufficiency arguments, it does not follow that the judges applied the sufficiency standard to the weight-of-the-evidence arguments.”); Moreland, 253 So. 3d at 1247 (explaining that the trial court’s ruling on the motion for new trial included two independent clauses that directly corresponded with the motion’s arguments and noting that the clause addressing the arguments that the verdict was contrary to the law and the weight of the evidence “simply denied the . . . motion without any comment”). Here, by contrast, the trial court explained why it denied Appellant’s motion for new trial and that explanation cannot be squared with the standard that is to be applied when ruling on a motion for new trial. Accord Baker v. State, 2018 WL 6803700 (Fla. 1st DCA Dec. 27, 2018) (distinguishing Bell and Moreland because the trial court’s “explicit reference to its rulings during trial” indicated that the court did not use the correct standard when ruling on the defendant’s motion for new trial).
Accordingly, we reverse and remand for reconsideration of the motion for new trial under the correct standard.
REVERSED and REMANDED for further proceedings.
WETHERELL, BILBREY, and M.K. THOMAS, JJ., concur. _____________________________ Not final until disposition of any timely and authorized motion under Fla. R. App. P. 9.330 or 9.331.
_____________________________ Andy Thomas, Public Defender, and Joanna Aurica Mauer, Assistant Public Defender, Tallahassee, for Appellant. Ashley Brooke Moody, Attorney General, and Daniel Krumbholz, Assistant Attorney General, Tallahassee, for Appellee.
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Citator
Authorities Cited
- Delbert Lee Tibbs v. State, 397 So. 2d 1120 (Fla. 1981)
- Bell v. State, 248 So. 3d 208 (Fla. 1st DCA 2018)
- Jordan v. State, 244 So. 3d 1178 (Fla. 1st DCA 2018)
- Moreland v. State, 253 So. 3d 1245 (Fla. 1st DCA 2018)