LEROY SLAUGHTER, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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Trial court reversibly erred by excluding defendant's alibi claim and witness list without first inquiring into the circumstances of noncompliance with discovery rules.
A trial court must inquire into the circumstances surrounding noncompliance with discovery rules before excluding alibi evidence and witness lists.
[1] Before excluding alibi evidence for noncompliance with discovery rules, a trial court must inquire into whether the violation was inadvertent or willful, trivial or subst…
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Court explaining that trial courts must investigate the reasons for discovery violations before excluding evidence
Defendant Slaughter was tried and the trial court excluded his alibi claim and supporting witness list without examining the reasons for noncompliance…
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PER CURIAM.
Upon review of the record on appeal and after due consideration of the briefs and oral argument we are constrained to hold that reversible error occurred when defendant’s claim of alibi and witness list in support thereof were excluded by the trial court without first inquiring into the surrounding circumstances. Barnes v. State, 294 So. 2d 679 (Fla.App.1974); Bell v. State, 287 So. 2d 717, (Fla.App.2d 1974); Williams v. State, 264 So. 2d 106 (Fla.App. 4th 1972). Any inquiry into a party’s failure to comply with Rule 3.200 FRCrP, should at least cover such questions whether the violation was inadvertent or willful, whether the violation was trivial or substantial, and most importantly what effect, if any, it had upon the ability of the other party to properly prepare for trial, i.e. prejudice or surprise. Barnes v. State, supra. A review of the totality of the circumstances of this case necessitates that the cause be reversed and remanded for a new trial. The issue is neither the trial court’s authority to impose sanctions nor waive non-compliance; but, rather, the necessity to first make an adequate inquiry into the circumstances surrounding noncompliance before discretion is exercised.
For the foregoing reasons the cause is reversed and remanded.
WALDEN, C. J., MAGER, J., and RUD-NICK, VAUGHN, J., Associate Judge, concur.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By
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Austin v. State, 461 So. 2d 1380 (Fla. 1st DCA 1984)…ome any such prejudice, we conclude that the trial court erred in ordering the exclusion of the subject witnesses. See Briseno v. State, 449 So. 2d 312 (Fla. 5th DCA 1984); Patterson v. State, 419 So. 2d 1120 (Fla. 4th DCA 1982); Slaughter v. State, 330 So. 2d 156 (Fla. 4th DCA 1976); Williams v. State, 264 So. 2d 106 (Fla. 4th DCA 1972); compare Lail v. State, 314 So. 2d 234 (Fla. 4th DCA 1975); and Chester v. State, 276 So. 2d 76 (Fla. 2nd DCA 1973). In light of the necessity of reversal for a new trial, w…
Authorities Cited
- Williams v. State, 264 So. 2d 106 (Fla. 4th DCA 1972)
- Bell v. State, 287 So. 2d 717 (Fla. 2d DCA 1974)
- Barnes v. State, 294 So. 2d 679 (Fla. 2d DCA 1974)