BRAD CAMERON WHITFIELD
v.
STATE OF FLORIDA

Fla. 1st DCA | 2021-09-15
No. 20-3736
Mallery
Florida District Court of Appeal, First District (2021)

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Holding

Standard-of-proof defects in a Stand-Your-Ground immunity hearing are cured when a defendant proceeds to trial and is convicted by a jury under the beyond-a-reasonable-doubt standard.


Headnotes

[1] A defect in the standard of proof applied at a Stand-Your-Ground immunity hearing is cured by a defendant's subsequent conviction at trial by a jury applying the beyond-a…

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Facts & Procedural History

Whitfield sought relief regarding a Stand-Your-Ground immunity hearing in which the standard of proof may have been deficient.…

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Opinion of the Court

September 15, 2021 PER CURIAM.

DENIED. See Boston v. State, 296 So. 3d 580, 583-84 (Fla. 1st DCA 2020) (finding standard-of-proof defects in a Stand-Your-Ground immunity hearing to have been cured after the defendant went to trial, raised a self-defense claim, and was convicted by a jury under the heavier trial burden of proof beyond a reasonable doubt), rev. granted, SC20-1164, 2020 WL 5946341 (Fla. Oct. 7, 2020)). LEWIS, OSTERHAUS, and KELSEY, JJ., concur. _____________________________ Not final until disposition of any timely and authorized motion under Fla. R. App. P. 9.330 or 9.331.

_____________________________ Robert R. Berry, Tallahassee, for Petitioner. Ashley Moody, Attorney General, and Quentin Humphrey, Assistant Attorney General, Tallahassee, for Respondent.


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