GOLDSBY
v.
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.
Christopher Goldsby was convicted of trafficking in methamphetamine and heroin and challenged the trial court's refusal to instruct the jury on the affirmative defense of lack of knowledge of the illicit nature of controlled substances. The appellate court affirmed, holding that since Goldsby's defense theory challenged possession rather than knowledge of the substance's nature, no evidence supported the affirmative defense instruction.
The trial court properly refused the jury instruction because no evidence supported the affirmative defense. Since Goldsby's defense strategy challenged possession rather than knowledge of the substance's nature, and Goldsby did not testify or present evidence establishing he was unaware of what the substance was, he was not entitled to the instruction.
[1] A defendant is entitled to a jury instruction on the affirmative defense of lack of knowledge of the illicit nature of a controlled substance when any evidence supports t…
[2] Knowledge of the illicit nature of a controlled substance is not an element of the crime of trafficking in methamphetamine or heroin.
Previewing 2 of 4 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“Knowledge of the illicit nature of a controlled substance is not an element of trafficking in methamphetamine or heroin. § 893.101(2), Fla. Stat. Lack of such knowledge is, instead, an affirmative defense.”
Establishes the legal distinction between knowledge of illicit nature as an affirmative defense versus a required element of the offense.
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceChristopher Goldsby was convicted of trafficking in methamphetamine and heroin. Goldsby did not testify at trial. The defense theory focused on challe…
The full statement of facts, procedural history, and disposition for this case are member content.
Join FLexlaw to unlock all legal intelligence© FLexlaw, Inc. — AI-generated enrichments are proprietary. All rights reserved.
evidence supports the theory, irrespective of how weak the evidence is.” Barnes v. State, 108 So. 3d 700, 702 (Fla. 1st DCA 2013) (citing Quick v. State, 46 So. 3d 1159, 1160 (Fla. 4th DCA 2010)).
Goldsby did not testify, and no other evidence supports the affirmative defense that he did not know the nature of the substance. Instead, the defense theory stressed that Goldsby did not knowingly possess the substances. That is, he challenged possession, not knowledge of the nature of the substance. Goldsby, therefore, was not entitled to a jury instruction on the lack of knowledge of the illicit nature of controlled substances.
AFFIRMED.
ROWE and NORDBY, JJ., concur.
_____________________________ Not final until disposition of any timely and authorized motion under Fla. R. App. P. 9.330 or 9.331.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- State v. Adkins, 96 So. 3d 412 (Fla. 2012)
- Barnes v. State, 108 So. 3d 700 (Fla. 1st DCA 2013)
- Quick v. State, 46 So. 3d 1159 (Fla. 4th DCA 2010)