ALONSO
v.
STATE OF FLORIDA
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The trial court did not abuse its discretion in admitting the challenged evidence, and any error in designating Alonso as a prison releasee reoffender and habitual felony offender is harmless beyond a reasonable doubt.
[1] A party need not renew an objection made in a motion in limine at trial to preserve a claim of evidentiary error for appeal when the trial court has made a definitive rul…
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Join FLexlaw to unlock all legal intelligenceJesse Alonso was convicted of resisting arrest with violence. He appealed challenging the admission of certain evidence at trial and the trial court's…
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DISTRICT COURT OF APPEAL OF FLORIDA
SECOND DISTRICT
JESSE ALONSO,
Appellant,
v.
STATE OF FLORIDA,
Appellee.
No. 2D2023-2304
July 9, 2025
Appeal from the Circuit Court for Pasco County; Mary M. Handsel, Judge.
Blair Allen, Public Defender, and Jeri Delgado, Assistant Public Defender, Bartow, for Appellant.
James Uthmeier, Attorney General, Tallahassee, and Helene S. Parnes, Senior Assistant Attorney General, Tampa, for Appellee.
SLEET, Judge.
Jesse Alonso appeals from his judgment and sentence for resisting arrest with violence. We find no merit in Alonso's argument that the trial court erred in admitting certain evidence at trial, and accordingly, we
1 Both Alonso and the State framed this argument as one of fundamental error. However, we need not conduct a fundamental error analysis as Alonso preserved this issue for appellate review by raising it in a motion in limine. See § 90.104(1), Fla. Stat. (2023) ("If the court has made a definitive ruling on the record admitting or excluding evidence, either at or before trial, a party need not renew an objection or offer of proof to preserve a claim of error for appeal." (emphasis added)); Suiter v. State, 2D2024-0337, 2025 WL 938602, at *1 (Fla. 2d DCA Mar. 28, 2025) ("The parties vigorously argued the motion in limine before trial. The trial court ruled. Mr. Suiter did not lodge an objection during [the witness's] trial testimony. . . . [A] contemporaneous objection would not have been out of line. But it was unnecessary." (underlined emphasis added) (citation omitted)); see also Cash v. State, 875 So. 2d 829, 832 n.3 (Fla. 2d DCA 2004) ("[A] party is no longer required to renew an objection made in a motion in limine at trial." (citing § 90.104(1), Fla. Stat. (2003))). Rather, we have concluded that the trial court did not abuse its discretion in making these evidentiary rulings. See Dessaure v. State, 891 So. 2d 455, 466 (Fla. 2004) ("A trial judge's ruling on the admissibility of evidence will not be disturbed absent an abuse of discretion.").
MORRIS and ROTHSTEIN-YOUAKIM, JJ., Concur.
Opinion subject to revision prior to official publication.
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Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Apprendi v. New Jersey, 530 U.S. 466 (U.S. 2000)
- Galindez v. State, 955 So. 2d 517 (Fla. 2007)
- Erlinger v. United States, 602 U.S. 821 (U.S. 2024)
- Dessaure v. State, 891 So. 2d 455 (Fla. 2004)
- Capra v. State, 403 So. 3d 1063 (Fla. 5th DCA 2025)
- Cash v. State, 875 So. 2d 829 (Fla. 2d DCA 2004)