JUAN BRIDON
v.
THE STATE OF FLORIDA
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A motion for judgment of acquittal made at the close of the State's evidence preserves the issue for appeal without requiring renewal after the defendant presents evidence, and public welfare offenses do not require proof of criminal intent.
[1] A motion for judgment of acquittal made at the close of the State's evidence preserves the issue for appeal without requiring the defendant to renew the motion after pres…
[2] Public welfare offenses, classified as mala prohibita crimes that typically result from neglect rather than conduct prohibited at common law, do not require proof of crim…
Previewing 2 of 2 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“[C]rimes proscribing conduct not prohibited at common law or crimes 'mala prohibita', which usually result from neglect, do not require any criminal intent.”
State v. Gruen, 586 So. 2d 1280, 1281 (Fla. 3d DCA 1991)
Juan Bridon was convicted in Miami-Dade County Court. The case involved a public welfare offense.…
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Third District Court of Appeal State of Florida Opinion filed April 9, 2025. Not final until disposition of timely filed motion for rehearing. No. 3D24-0390 Lower Tribunal No. B23-15795 Juan Bridon, Appellant, vs. The State of Florida, Appellee. An Appeal from the County Court for Miami-Dade County, Cristina Rivera Correa, Judge. Carlos J. Martinez, Public Defender, and Maria Lauredo, Chief Assistant Public Defender, for appellant. James Uthmeier, Attorney General, and Daniel Colmenares, Assistant Attorney General, for appellee. Before EMAS, FERNANDEZ and MILLER, JJ.
PER CURIAM.
Affirmed. See Morris v. State, 721 So. 2d 725, 726-27 (Fla. 1998)
(finding that a motion for judgment of acquittal can be made at the close of the State’s evidence, and in order to preserve the issue for appeal, the defendant is not required to renew the motion after the defendant has presented evidence); Morissette v. United States, 342 U.S. 246, 255-56 (1952) (stating that a certain class of “public welfare offenses” do not require intent); State v. Gruen, 586 So. 2d 1280, 1281 (Fla. 3d DCA 1991) (“[C]rimes proscribing conduct not prohibited at common law or crimes ‘mala prohibita’, which usually result from neglect, do not require any criminal intent.”).
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Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Morissette v. United States, 342 U.S. 246 (U.S. 1952)
- Morris v. State, 721 So. 2d 725 (Fla. 1998)
- State v. Gruen, 586 So. 2d 1280 (Fla. 3d DCA 1991)