Bedward v. State
On remand from the Florida Supreme Court's decision in Oquendo v. State (Oquendo II), which held PTSD evidence 'may be relevant' to the subjective component of self-defense (overruling the categorical-irrelevance rule from Oquendo I that the 4th DCA had originally relied on), the court reconsidered but again affirmed. The court held that without expert testimony connecting the defendant's PTSD to the charged incident, and without the safeguards described in Mizell (defendant testifying and laying a predicate, limited expert testimony, no vouching), the trial court properly excluded the PTSD evidence, and separately found the defendant was the aggressor with a duty to retreat, defeating any self-defense theory regardless.
Key facts
- Defendant was charged with a crime and claimed self-defense, asserting that PTSD evidence was relevant to his subjective fear at the time of the incident.
- The trial court excluded the defendant's PTSD evidence and did not provide a self-defense instruction; the defendant was convicted.
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Why it matters
This is the 4th DCA's first application of the Florida Supreme Court's Oquendo II decision resolving the First/Second District conflict over PTSD evidence in self-defense cases, and it gives concrete guidance on what… — full analysis with a trial
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