D.W. v. State
In a juvenile delinquency appeal, the Second DCA held that the trial court properly applied the Florida Supreme Court's retroactive administrative order suspending speedy-trial deadlines due to Hurricane Ian, even though the order issued after the deadline for a discharge hearing had passed, because the hearing was held on the first day courts reopened. The court also found no fundamental error in the trial judge directing questioning to establish a recollection-refreshing foundation, and found any error in admitting an unauthenticated photograph harmless. However, the court reversed and remanded for a new adjudicatory hearing because the State's discovery disclosure of a report referencing fingerprint photographs did not satisfy its obligation to disclose the photographs themselves, and the trial court's Richardson inquiry was inadequate and its no-violation finding unsupported by the record.
Key facts
- D.W., a juvenile, was charged with delinquency; the trial court held an adjudicatory hearing and found D.W. violated the charged offenses.
- The State failed to disclose fingerprint photographs themselves, disclosing only a report that referenced their existence, and the trial court conducted an inadequate Richardson inquiry that did not address how the nondisclosure affected the defense's trial preparation.
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Why it matters
This opinion gives practitioners a rare data point on how retroactively-issued administrative orders suspending speedy-trial deadlines during court closures (e.g., hurricanes) apply to juvenile discharge-motion… — full analysis with a trial
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