Dwayne Lee Lewis v. State of Florida
The Sixth DCA affirmed Lewis's conviction, holding it was bound by Carr v. State to treat the evidentiary challenge as unpreserved because Lewis did not renew his objection at trial despite an adverse pretrial ruling. Recognizing the tension between Carr and the plain language of section 90.104(1) — which states that a definitive pretrial ruling makes renewal unnecessary — the court certified a question of great public importance to the Florida Supreme Court.
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