Forbes v. State (consolidated with Delancy v. State and Ingraham v. State)
Three co-defendants convicted of first-degree murder of a sheriff's deputy, attempted murder of another deputy, and conspiracy, appealed denial of their motions to sever their joint trial along with suppression and other trial rulings. The Fourth DCA affirmed across the board but wrote specifically to address the severance issues, finding no abuse of discretion in denying severance based on exclusion of co-defendant 'other crimes' evidence, a co-defendant's surprise opening-statement defense, exclusion of a non-inculpatory hearsay statement, antagonistic defenses, and DNA expert cross-examination.
Key facts
- Three co-defendants were jointly tried and convicted of first-degree murder of a sheriff's deputy, attempted murder of another deputy, and conspiracy.
- Each defendant moved to sever their trial, arguing that co-defendants' 'other crimes' evidence, antagonistic defenses, surprise opening statements, and excluded statements prejudiced their right to a fair trial.
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Why it matters
This opinion is a useful practitioner reference for multi-defendant murder/violent-crime cases where severance is sought based on antagonistic defenses, exclusion of co-defendant statements, or Williams-rule-type… — full analysis with a trial
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