1D2025-1776
The First DCA reversed two of Crowley's convictions for promoting a sexual performance by a child for insufficient evidence (impermissible pyramiding of inferences) but affirmed a third where forensic evidence converged without stacked inferences. On double jeopardy, the court held that Lee v. State's charging-document-only rule applies only where offenses are legally the same due to statutory subsumption (as in Lee itself), and does not extend to multiple convictions under the identical statute, where courts may look to the trial record to determine factual distinctness. The court certified conflict with the Second DCA's Dominguez decision, which had applied Lee's rule to same-statute prosecutions.
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Key facts
- Crowley was convicted of three counts of promoting a sexual performance by a child based on digital evidence, including images found on a shared device and online accounts.
- At trial, the State relied on inferences about device ownership, image creation, and Crowley's participation in depicted events to establish the charges.
- +2 more key facts with a free trial
Why it matters
This opinion directly addresses a live, certified district conflict over a recurring double-jeopardy scenario: multiple convictions charged in identical language under the same statute for overlapping time periods… — full analysis with a trial
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