Cowins v. State
The Fourth DCA affirmed a second-degree murder conviction, holding that expert testimony that the defendant suffered from PTSD was properly excluded because it was irrelevant to his self-defense claim under Florida's objective reasonableness standard. The court expressly adopted the Second District's reasoning in Oquendo v. State and certified conflict with the First District's contrary holding in State v. Mizell, noting the Florida Supreme Court has already accepted jurisdiction in Oquendo.
Key facts
- Defendant Cowins was convicted of second-degree murder in the trial court.
- Defendant sought to introduce expert testimony that he suffered from PTSD to support a self-defense claim, arguing the condition heightened or altered his perception of danger.
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Why it matters
This decision squarely addresses a live, high-stakes district conflict over whether PTSD (or similar psychological) evidence is admissible in support of self-defense claims, an issue now pending before the Florida… — full analysis with a trial
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