3D2023-1684
An off-duty police officer convicted of battery and trespass challenged the trial court's exclusion of cross-examination testimony about the alleged victim's drug and alcohol use before the incident, offered to impeach her credibility and support a self-defense theory. The Third DCA held that the trial court abused its discretion in excluding the evidence because Satchell's own testimony that she was impaired, along with her belligerent behavior, provided sufficient corroborating evidence of contemporaneous intoxication under Green v. State and Edwards v. State, making the exclusion reversible error under DiGuilio's harmless error standard.
Key facts
- An off-duty police officer was convicted of battery and trespass after an altercation with a woman at a bar.
- The trial court excluded cross-examination evidence about the alleged victim's prior drug and alcohol use, which the officer sought to use for impeachment and to support a self-defense claim.
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Why it matters
This decision clarifies application of the Green/Edwards corroboration standard for admitting intoxication-based impeachment evidence, confirming that a witness's own admission of impairment plus corroborating conduct… — full analysis with a trial
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