ROBINSON CALIXTE
v.
THE STATE OF FLORIDA
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Robinson Calixte appeals his conviction, raising an issue regarding expert witness testimony at trial. The Third District affirmed the conviction while providing guidance on the admissibility of expert testimony regarding a defendant's mental condition and ability to understand rights.
The court affirmed the conviction, holding that an expert cannot testify as to the truthfulness of a witness or to a defendant's mental condition when such condition is not at issue at trial. However, where a defendant's mental condition is at issue—such as the ability to understand and competently waive Miranda rights—expert testimony on that specific condition may be admissible.
[1] An expert witness is precluded from testifying as to the credibility or truthfulness of another witness or to a criminal defendant's mental condition when such mental con…
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 expert cannot testify as to the truthfulness of a witness or to a defendant's mental condition when such condition is not at issue”
States the general rule against expert testimony on witness credibility and irrelevant mental conditions
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Join FLexlaw to unlock all legal intelligenceCalixte was convicted in the Circuit Court for Miami-Dade County. The case involved a question about whether expert testimony concerning the defendant…
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Opinion filed January 29, 2025. Not final until disposition of timely filed motion for rehearing.
________________ No. 3D24-0270 Lower Tribunal No. F17-9011 ________________
Robinson Calixte,
Appellant,
vs.
The State of Florida,
Appellee.
An Appeal from the Circuit Court for Miami-Dade County, Marisa Tinkler Mendez, Judge. Carlos J. Martinez, Public Defender, and Susan S. Lerner, Assistant Public Defender, for appellant. John Guard, Acting Attorney General, and Sandra Lipman, Senior Assistant Attorney General, for appellee. Before EMAS, LINDSEY and BOKOR, JJ. PER CURIAM.
Affirmed. See Erickson v. State, 565 So. 2d 328, 331 (Fla. 4th DCA 1990) (explaining that an expert cannot testify as to the truthfulness of a witness or to a defendant’s mental condition when such condition is not at issue); see also Carter v. State, 697 So. 2d 529, 531 (Fla. 1st DCA 1997) (reversing based on exclusion of defense expert testimony where defense expert would have testified to Carter’s mental condition and ability to understand his rights pursuant to Miranda v. Arizona, 384 U.S. 436 (1966), and competently waive same).
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Miranda v. Arizona, 384 U.S. 436 (U.S. 1966)
- Erickson v. State, 565 So. 2d 328 (Fla. 4th DCA 1990)
- Tavares Burks v. State, 697 So. 2d 529 (Fla. 2d DCA 1997)