CHARLES WILLIAMS, APPELLANT,
v.
THE STATE OF FLORIDA, APPELLEE
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Charles Williams was convicted of first-degree murder in a non-jury trial and sentenced to life in prison. He appealed on three grounds: denial of grand jury testimony access, erroneous sanity finding, and insufficient evidence. The appellate court affirmed the conviction, finding no error in the trial court's decisions.
The court held that (1) the trial judge properly denied access to grand jury testimony where no material discrepancies were found, following established precedent; (2) where evidence on sanity is conflicting, the trier of fact may resolve the conflict in favor of sanity, even when that conflicts with expert psychiatric testimony; and (3) the conviction was supported by the evidence.
[1] A trial court is not required to provide defense counsel with grand jury testimony if the judge finds only inconsequential discrepancies between the testimony and trial s…
[2] Where evidence regarding a defendant's sanity is in conflict, it is within the province of the trier of fact to resolve the conflict in favor of the defendant's sanity.
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Join FLexlaw to unlock all legal intelligence“if the trial judge finds in grand jury testimony merely unconsequential deviations, he is not required to provide the cross-examiner a basis for ranging over a wide area of collateral and minute detail”
Establishes the standard for denying defense access to grand jury testimony—only material discrepancies warrant disclosure.
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Join FLexlaw to unlock all legal intelligenceWilliams was tried without a jury and convicted of first-degree murder. He was sentenced to life imprisonment. Defense counsel requested the transcrip…
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The appellant was tried non-jury, convicted of murder in the first degree and sentenced to life in prison. He appeals and urges error in the following particulars: (1) It was error to deny the defendant access to grand jury testimony; (2) it was error to find the defendant legally sane at the time of the commission of the crime; (3) the conviction was not supported by the evidence.
Turning to point one, we find no error. Defense counsel requested the transcript of grand jury testimony of one Frank Young whose testimony at trial was conflicting. The grand jury testimony was reviewed in camera by the trial judge, who, unable to find any material discrepancies, refused to release it to defense counsel. This procedure is in accord with Minton v. State, Fla.1959, 113 So.2d 361, which is controlling. In Minton the Florida Supreme Court held that if the trial judge finds in grand jury testimony merely unconsequential deviations, he is not required to provide the cross-examiner a basis for ranging over a wide area of collateral and minute detail. See also Jackman v. State, Fla.App. 1962, 140 So.2d 627.
As to the second point, the defendant’s sanity, the evidence was in conflict. Two doctors testified that the defendant was unable to distinguish right from wrong at the time of the offense. However, one of the doctors expressed his opinion as a reasonable medical probability rather than a certainty. He also further qualified his opinion. In addition, the arresting officers testified to the effect that at the time of arrest they thought defendant to be normal. It is well established that where evidence as to defendant’s sanity is in conflict, it is within the province of the trier of fact to resolve the conflict in favor of the sanity of the defendant. French v. State, Fla.App.1972, 266 So.2d 51; Sallavirta v. State, Fla.App.1968, 210 So.2d 487; Crum v. State, Fla.App.1965, 172 So.2d 24. The above statement is true even where the conflict is between the testimony of lay witnesses and the opinions of psychiatrists. See Blatch v. State, Fla.App.1968, 216 So.2d 261; Brady v. State, Fla.App.1966, 190 So.2d 607; Byrd v. State, Fla.App.1965, 178 So.2d 886; Norman v. State, Fla.App.1963, 156 So.2d 186.
*286We have considered appellant’s third point on appeal and find that to be without merit.
Accordingly, the judgment of the lower court is hereby affirmed.
Affirmed.
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Grady Nelson v. State, 362 So. 2d 1017 (Fla. 3d DCA 1978)…o. 2d 361 (Fla.1959). Therefore, we are of the view that the trial judge did not abuse his discretion in denying the defense access to the grand jury testimony, as such testimony did not amount to favorable and material evidence. Williams v. State, 275 So. 2d 284 (Fla.3d DCA 1973). [*1021] POINT III Whether the trial judge erred in denying motions for mistrial and new trial when a prosecution witness, on cross-examination, volunteered testimony which implied that appellant had been involved in unrelated cri…
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Benson v. State, 526 So. 2d 948 (Fla. 2d DCA 1988)…y largely could not “be raised to the ‘favorable evidence’ status as per Brady ” and were “inconsequential deviations.” Nelson v. State, 362 So. 2d 1017, 1020 (Fla.3d DCA 1978). See also Minton v. State, 113 So. 2d 361 (Fla.1959); Williams v. State, 275 So. 2d 284 (Fla.3d DCA 1973). The information as to the difference between the sister’s descriptions of defendant’s demeanor has given us pause for especially close attention. But we do not conclude that that aspect calls for reversal. [*958] That difference…
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Delma Davis v. State, 319 So. 2d 611 (Fla. 3d DCA 1975)…the sanity of the defendant even where the conflict is between the testimony of lay witnesses and opinions of psychiatrists. See Byrd v. State, Fla.1974, 297 So. 2d 22; Clayton v. State, Fla.App.1973, 272 So. 2d 860; Williams v. State, Fla.App.1973, 275 So. 2d 284; Bethel v. State, Fla.App.1974, 305 So. 2d 251. [*613] There being conflicting testimony as to the sanity of the defendant-appellant in the case sub judice, it was within the province of the jury to determine this question of fact and we will not di…
Previewing 3 of 5 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Crum v. State, 172 So. 2d 24 (Fla. 3d DCA 1965)
- Jackman v. State, 140 So. 2d 627 (Fla. 3d DCA 1962)
- Minton v. State, 113 So. 2d 361 (Fla. 1959)
- Blatch v. State, 216 So. 2d 261 (Fla. 3d DCA 1968)
- Byrd v. State, 178 So. 2d 886 (Fla. 2d DCA 1965)
- Norman v. State, 156 So. 2d 186 (Fla. 3d DCA 1963)
- Brady v. State, 190 So. 2d 607 (Fla. 3d DCA 1966)
- French v. State, 266 So. 2d 51 (Fla. 3d DCA 1972)
- Erro Sallavirta v. State, 210 So. 2d 487 (Fla. 3d DCA 1968)