Juan Javier Oquendo v. State
The Florida Supreme Court resolved a certified conflict between the First and Second Districts over whether expert PTSD testimony can ever be relevant to a self-defense claim. The Court held that Florida's self-defense standard has both an objective (reasonable person) and a subjective (actual belief) component, and that PTSD evidence may be relevant to the subjective component even though it is categorically irrelevant to the objective component, approving Mizell and disapproving Oquendo on that point. Despite this ruling in Oquendo's favor on the legal question, the Court affirmed his manslaughter conviction because his own testimony (accidental discharge) and counsel's diminished-capacity-flavored argument meant the trial court did not abuse its discretion in excluding the PTSD expert.
Key facts
- Defendant Oquendo shot and killed another person; he testified the shooting was accidental, but the State charged him with manslaughter.
- The trial court excluded expert testimony on Oquendo's PTSD, and he was convicted of manslaughter.
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Why it matters
This is a significant, precedent-setting opinion for Florida criminal practitioners litigating self-defense and Stand Your Ground cases: it definitively establishes that Florida's self-defense test is a hybrid… — full analysis with a trial
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