STATE OF FLORIDA
v.
JAMARLIN HUNTLEY
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When circumstantial evidence requires stacking at least two inferences to prove the intentional act element of child abuse, the evidence is insufficient to support a conviction.
[1] In a prosecution based on circumstantial evidence, a conviction cannot rest upon the stacking or pyramiding of multiple inferences from the evidence presented.
Previewing 1 of 1 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“An impermissible pyramiding of inferences occurs where at least two inferences in regard to the existence of a criminal act must be drawn from the evidence and then stacked to prove the crime charged; in that scenario, it is said that the evidence lacks the conclusive nature to support a conviction.”
Court explaining the legal test for sufficiency of circumstantial evidence, citing Graham v. State.
Defendant Huntley was charged with child abuse of a minor under 18. The state presented only circumstantial evidence regarding whether defendant commi…
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PER CURIAM.
The state appeals an order granting the defendant’s motion for judgment of acquittal.1 To prove the charged offense of child abuse, the state was required to prove that (1) the defendant committed “[a]n intentional act that could reasonably be expected to result in physical or mental injury to” K.H., and (2) that K.H. was under 18. See §§ 827.01(2), 827.03(1)(b)2., Fla. Stat. (2017). On the entirely circumstantial evidence before us as to the commission of the act, we cannot conclude that the defendant committed an intentional act without impermissibly stacking inferences. See generally Graham v. State, 748 So. 2d 1071, 1072 (Fla. 4th DCA 1999) (“An impermissible pyramiding of inferences occurs where
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at least two inferences in regard to the existence of a criminal act must be drawn from the evidence and then stacked to prove the crime charged; in that scenario, it is said that the evidence lacks the conclusive nature to support a conviction.”). In light of Bush v. State, 295 So. 3d 179 (Fla. 2020), we are aware that the jurisprudence regarding inference stacking may evolve, but at this point we are bound to follow the dictates of precedent. Accordingly, we affirm. Affirmed. GROSS, CIKLIN, JJ., and BELL, CAROLYN, Associate Judge, concur.
* * * Not final until disposition of timely filed motion for rehearing.
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Authorities Cited
- Bush v. State, 295 So. 3d 179 (Fla. 2020)
- Graham v. State, 748 So. 2d 1071 (Fla. 4th DCA 1999)
- State v. Jamaal Pickersgill, 284 So. 3d 542 (Fla. 4th DCA 2019)