DWIGHT HATFIELD, APPELLANT,
v.
MICHAEL J. YORK, APPELLEE
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.
Hatfield sued York for damages arising from criminal charges, pleading guilty to the underlying offenses. The court held that Hatfield's guilty pleas do not bar civil claims for assault and battery or false arrest, but do bar a malicious prosecution claim, which requires a favorable termination of the criminal charges.
The court held that guilty pleas do not bar civil claims for assault and battery or false arrest, which can proceed despite the guilty plea, but guilty pleas do bar a malicious prosecution claim because an essential element of malicious prosecution is a favorable termination of the criminal charges, which did not occur here.
[1] A guilty plea to a criminal offense is admissible in a civil action as a declaration against interest and may be considered by the finder of fact, but it does not as a ma…
[2] A guilty plea to criminal charges arising from an incident does not necessarily vitiate civil claims for assault and battery or false arrest stemming from the same incide…
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“In civil actions where one of the issues is the guilt of a person convicted of a criminal offense, or some fact necessarily involved in the determination of such guilt, it is proper to admit evidence of that person's plea of guilty to the criminal offense. The guilty plea is admissible as a declaration against interest and may be considered by the finder of fact, but it does not as a matter of law establish the truth of the facts upon which the judgment of guilt was rendered.”
Establishes the evidentiary standard for guilty pleas in civil cases—they are admissible but not conclusive proof of guilt.
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceHatfield filed a three-count amended counterclaim against York for assault and battery, false arrest, and malicious prosecution. Hatfield alleged that…
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ALDERMAN, Chief Judge.
In a three-count amended counterclaim appellant seeks damages for assault and battery, false arrest and malicious prosecution. The trial court dismissed with prejudice all three counts because appellant alleged that he pled guilty to assault and battery, resisting arrest without violence and indecent exposure, the same criminal charges which he alleged were maliciously instituted by the appellee. He attempts to avoid the effect of his previous pleas of guilty by alleging that the pleas were procured through fraud, perjury or other corrupt means, contending that the finder of fact should be allowed to weigh the guilty pleas as evidence in the case.
In civil actions where one of the issues is the guilt of a person convicted of a criminal offense, or some fact necessarily involved in the determination of such guilt, it is proper to admit evidence of that person’s plea of guilty to the criminal offense. The guilty plea is admissible as a declaration against interest and may be considered by the finder of fact, but it does not as a matter of law establish the truth of the facts upon which the judgment of guilt was rendered. Boshnack v. World Wide Rent-A-Car, Inc., 195 So. 2d 216 (Fla.1967).
In the present case, counts one and two allege causes of action which are not vitiated by appellant’s admission that he pled guilty to certain criminal charges arising out of the same incident. In spite of appellant’s guilty pleas, he may still be able to present evidence from which a jury could find that he was the victim of an assault and battery and a false arrest.
A different situation exists, however, as to count three. An essential element of malicious prosecution is a bona fide termination of the original criminal charges in favor of the claimant. The original criminal charges in this case obviously were not terminated in appellant’s favor because he pled guilty. The deficiency is not cured by the allegation that these pleas were procured through fraud, perjury or other corrupt means.
We hold that the trial court erred in dismissing counts one and two for assault and battery and false arrest, but correctly dismissed count three for malicious prosecution.
AFFIRMED in part, REVERSED in part, and REMANDED.
DREW, E. HARRIS (Retired), and STET-TIN, HERBERT, Associate Judges, concur.
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Nell v. Int'l Union OF Operating Eng'rs, 427 So. 2d 798 (Fla. 4th DCA 1983)…a contest which results in a final decision of a court of competent jurisdiction. 354 So. 2d at 374 (footnotes omitted). . Boshnack v. World Wide Rent-A-Car, Inc., 195 So. 2d 216 (Fla.1967). See also the decision of this court in Hatfield v. York, 354 So. 2d 426, 427 (Fla. 4th DCA 1978), which noted that the guilty plea “does not as a matter of law establish the truth of the facts upon which the judgment of guilt was rendered.” . Eggers v. Phillips Hardware Co., 88 So. 2d 507 (Fla.1956) (en banc); Moseley…
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Nunez v. Estrella Gonzalez, 456 So. 2d 1336 (Fla. 2d DCA 1984)…ever, a judgment entered in a criminal prosecution on a plea of guilty may be introduced in a civil action to establish an admission against interest. Boshnack v. World Wide Rent-A-Car, Inc., 195 So. 2d 216 (Fla.1967). The court in Hatfield v. York, 354 So. 2d 426 (Fla. 4th DCA 1978), reversed an order which had dismissed a complaint for assault and battery and false arrest because the plaintiff had pled guilty to criminal charges arising out of the incident upon which the complaint was based. The court state…
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The Bank OF Montreal & Harris, N.A. v. The Est. OF Jacques Antoine, 86 So. 3d 1262 (Fla. 4th DCA 2012)…fense. The guilty plea is admissible as a declaration against interest and may be considered by the finder of fact, but it does not as a matter of law establish the truth of the facts upon which the judgment of guilt was rendered. Hatfield v. York, 354 So. 2d 426, 427 (Fla. 4th DCA 1978). In the present case, Antoine’s plea agreement detailed that Antoine “caused Harris to issue checks payable to ... individuals and entities from whom defendant and Individual A [Crowder] purchased or intended to purchase as…
Authorities Cited
- S. Broward Hosp. Dist. v. Schmitt, 195 So. 2d 216 (Fla. 1967)
- Boshnack v. World Wide Rent-A-Car, Inc., 195 So. 2d 216 (Fla. 1967)