A.C. v. State
The Third DCA held that misdemeanor culpable negligence under section 784.05(1) does not require the State to prove a 'likelihood of death or great bodily harm,' rejecting the appellant's argument that the term 'culpable negligence' must be interpreted uniformly across the manslaughter, child neglect, and culpable negligence statutes. The court affirmed the juvenile's adjudication (withhold with judicial warning) for smearing deodorant gel around a classroom that caused a teacher to slip and fall, finding the conduct sufficiently showed reckless disregard for the safety of others to satisfy the lower 'personal injury' threshold in section 784.05(1).
Key facts
- Juvenile was adjudicated for misdemeanor culpable negligence under section 784.05(1) after smearing deodorant gel around a classroom, causing a teacher to slip and fall.
- Trial court denied juvenile's motion for judgment of acquittal and entered an adjudication with withhold of adjudication and judicial warning.
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Why it matters
This opinion resolves, for the first time in the Third DCA, a recurring statutory interpretation question about the scope of misdemeanor culpable negligence under section 784.05(1), clarifying that the more demanding… — full analysis with a trial
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