Etienne v. State

The Fourth DCA held that the trial court erred by failing to conduct a Richardson hearing after the victim testified he had given allegedly threatening messages to a prior prosecutor that were never disclosed to the defense, but found the error harmless because the defendant admitted to the battery, video evidence corroborated the victim's account, and the undisclosed messages did not affect her self-defense trial strategy. The court reiterated that a possible discovery violation triggers the Richardson requirement regardless of whether the state's current trial prosecutor was personally aware of the evidence (constructive knowledge applies) and regardless of whether the trial court believes the violation was unintentional or non-prejudicial to the defendant.

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