K.D. v. State
The Sixth DCA reversed a juvenile's withheld adjudication for possession of child pornography because the trial court failed to conduct a Richardson hearing after the State committed a discovery violation by failing to disclose Kik records it intended to use as evidence. The court held that merely referencing the existence of evidence in a police report does not satisfy the State's disclosure obligations under Florida Rule of Juvenile Procedure 8.060, and applied the Schopp harmless error standard to find the violation was not harmless beyond a reasonable doubt.
Key facts
- K.D., a juvenile, was charged with possession of child pornography; the trial court withheld adjudication after K.D. confessed to the offense.
- The State failed to specifically disclose Kik records it intended to use as evidence at the adjudicatory hearing, instead only referencing their existence in a disclosed police report.
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Why it matters
This opinion clarifies that in juvenile delinquency proceedings, the State cannot satisfy its Rule 8.060 discovery obligations by burying reference to key physical evidence within a generally-disclosed police report; it… — full analysis with a trial
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