ZACHARY JOSEPH PENNA
v.
STATE OF FLORIDA

Fla. 4th DCA | 2025-04-30
No. 2020-0345
Shepherd, C.J., Gerber, J., Warner, J., Artau, J.
2025 FL 3670 Florida District Court of Appeal, Fourth District (2025)

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Holding

A question of great public importance is certified to the Florida Supreme Court regarding whether a defendant's Fifth Amendment Miranda rights are automatically violated when an officer fails to re-read a Miranda warning following the defendant's voluntary re-initiation of contact.


Headnotes

[1] A question of whether a defendant's Fifth Amendment Miranda rights are automatically violated when an officer fails to re-read a Miranda warning following the defendant's…

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Facts & Procedural History

Zachary Joseph Penna appealed a conviction from the Circuit Court for the Fifteenth Judicial Circuit in Palm Beach County. The appeal involved issues …

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Opinion of the Court
S Motion For Certification Of A Question Of Great Public Importance Or Rehearing En Banc Gerber

DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA

FOURTH DISTRICT

ZACHARY JOSEPH PENNA, Appellant,

v.

STATE OF FLORIDA, Appellee.

No. 4D20-345

[March 9, 2022]

Appeal from the Circuit Court for the Fifteenth Judicial Circuit, Palm Beach County; Caroline

C.

Shepherd, Judge;

L.T.

Case No. 502016CF006304A.

Carey Haughwout, Public Defender, and Paul Edward Petillo, Assistant Public Defender, West Palm Beach, for appellant.

Ashley Moody, Attorney General, Henry C. Whitaker, Solicitor General, Jeffrey Paul DeSousa, Chief Deputy Solicitor General, and Evan Ezray, Deputy Solicitor General, Tallahassee, for appellee.

ON APPELLEE’S MOTION FOR CERTIFICATION OF A QUESTION OF

GREAT PUBLIC IMPORTANCE OR REHEARING EN BANC

GERBER, J.

After consideration of the state’s motion for certification of a question of great public importance, and the defendant’s response thereto, we grant the state’s motion for certification of a question of great public importance. We certify to the Florida Supreme Court the following question of great public importance:

WHETHER A DEFENDANT’S FIFTH AMENDMENT MIRANDA

RIGHTS ARE AUTOMATICALLY VIOLATED WHEN AN

OFFICER FAILS TO RE-READ A MIRANDA WARNING

FOLLOWING A DEFENDANT’S VOLUNTARY RE-INITIATION

OF CONTACT.

2

In view of our having certified the state’s requested question of great public importance, the state’s alternative motion for rehearing en banc, which requested the same certification, is denied as moot.

WARNER and ARTAU, JJ., concur.

* * *

No further motion for rehearing shall be filed.


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