ANISSA NICOLE SANANTONIO
v.
THE STATE OF FLORIDA
AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.
The Third District Court of Appeal affirmed the lower court's decision, holding that the standard of review for the legal sufficiency of evidence in a criminal conviction is whether competent, substantial evidence supports the conviction, allowing a rational trier of fact to find guilt beyond a reasonable doubt.
The appellate court held that the "special" standard of review for circumstantial evidence cases has been abolished. The standard is now whether the State presented competent, substantial evidence, and if, viewing that evidence favorably to the State, a rational trier of fact could find the elements of the crime established beyond a reasonable doubt.
[1] The circumstantial evidence standard of review for a motion for judgment of acquittal applies only when all of the evidence of a defendant's guilt is circumstantial, not…
[2] Direct evidence is testimony of a witness's own knowledge of the facts at issue, while circumstantial evidence allows an inference of disputed facts from proven facts and…
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Join FLexlaw to unlock all legal intelligence“abolishing the “special” standard of appellate review for circumstantial evidence cases, and holding that the standard of review to be applied to a determination of the legal sufficiency of evidence in support of a criminal conviction (regardless of the circumstantial nature of the evidence) is whether the State presented competent, substantial evidence and, viewing that evidence in the light most favorable to the State, whether a rational trier of fact could have found the State established the elements of the crime beyond a reasonable doubt.”
This quote explains the new standard of review for the legal sufficiency of evidence in criminal convictions.
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Join FLexlaw to unlock all legal intelligenceThe specific facts of the underlying criminal case are not detailed in this opinion. The case involves an appeal by Anissa Nicole Sanantonio against t…
The full statement of facts, procedural history, and disposition for this case are member content.
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Third District Court of Appeal
State of Florida
Opinion filed July 7, 2021. Not final until disposition of timely filed motion for rehearing.
________________
No. 3D21-261 Lower Tribunal Nos. M19-12920, 20-29 AC
________________
Anissa Nicole Sanantonio,
Appellant,
vs.
The State of Florida,
Appellee.
An Appeal from the County Court for Miami-Dade County, Christine Bandin, Judge. Carlos J. Martinez, Public Defender, and Susan S. Lerner, Assistant Public Defender, for appellant. Katherine Fernandez Rundle, State Attorney, and Lindsey M. Johnson, Assistant State Attorney; Ashley Moody, Attorney General, and Ivy R. Ginsberg, Assistant Attorney General, for appellee. Before EMAS, HENDON and MILLER, JJ.
PER CURIAM.
Affirmed. See J.B. v. State, 73 So. 3d 361 (Fla. 3d DCA 2011); State v. Clyatt, 976 So. 2d 1182 (Fla. 5th DCA 2008). See also Bush v. State, 295 So. 3d 179, 200-01 (Fla. 2020) (abolishing the “special” standard of appellate review for circumstantial evidence cases, and holding that the standard of review to be applied to a determination of the legal sufficiency of evidence in support of a criminal conviction (regardless of the circumstantial nature of the evidence) is whether the State presented competent, substantial evidence and, viewing that evidence in the light most favorable to the State, whether a rational trier of fact could have found the State established the elements of the crime beyond a reasonable doubt).
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Worcester v. Commissioner OF Internal Revenue, 370 F.2d 713 (1st Cir. 1966)…rt’s view was that a conviction for filing a false return with intent to evade tax did not form the basis for collateral estoppel. Meyer J. Safra, 1958, 30 T.C. 1026; Eugene Vassallo, 1955, 23 T.C. 656. It changed its position in 1964. John W. Amos, 43 T.C. 50, aff’d, 4 Cir., 1965, 360 F. 2d 358. . It is questionable, at best, whether petitioners can so characterize their failure to rely on this defense, assuming, which we in no way intimate, it could have been valid. The latest of the cited cases was de…
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Haldane M. Plunkett v. Commissioner OF Internal Revenue, 465 F.2d 299 (7th Cir. 1972)…7 L.Ed.2d 541 (1967); Armstrong v. United States, 354 F. 2d 274, 173 Ct.Cl. 944 (1965); Tomlinson v. Lefkowitz, 334 F. 2d 262 (5th Cir. 1964), cert. denied, 379 U.S. 962, 85 S.Ct. 650, 13 L.Ed.2d 556 (1965); Amos v. Commissioner of Internal Revenue, 43 T.C. 50 (1964), aff’d, 360 F. 2d 358 (4th Cir. 1965). Two recent decisions of the Tax Court reiterate this principle, C.B.C. Super Markets, Inc. v. Commissioner of Internal Revenue, 54 T.C. 882 (1970), and Rodney v. Commissioner of Internal Revenue, 53 T.C.…
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Armstrong v. The United States, 354 F.2d 274 (Ct. Cl. 1965)…court concluded “that the issue of the existence of a fraudulent intent is foreclosed by collateral estoppel arising from Sidney’s conviction under section 145(b).” 334 F. 2d at 266. On October 21, 1964, the Tax Court held, in Amos v. Commissioner, 43 T.C. 50, that: In the instant case imposition of the civil penalty * * * depends upon a determination of the ultimate fact that petitioner’s underpayment of tax for the years 1955 through 1958 was due to fraud. This ultimate fact for determination herein i…
Previewing 3 of 6 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Bush v. State, 295 So. 3d 179 (Fla. 2020)
- State v. Clyatt, 976 So. 2d 1182 (Fla. 5th DCA 2008)
- First Quality Gasoline, Inc. v. Motiva Enters., LLC, 73 So. 3d 361 (Fla. 3d DCA 2011)