Middlebrook v. State
The Sixth DCA held that the trial court violated the defendant's Sixth Amendment confrontation right by precluding cross-examination of the State's key witness about a prior police report the defendant made against him for possessing child pornography, which was offered to show the witness's bias and motive to lie. Because this was a different and more serious ground for bias than another motive already presented to the jury, and the State failed to argue the error was harmless, the court reversed the conviction and remanded for a new trial.
Key facts
- Defendant Middlebrook was convicted in trial court after the judge precluded cross-examination of the State's key witness regarding a prior police report the defendant had made against the witness for possessing child pornography.
- The defendant sought to use the prior report to demonstrate the witness's bias and motive to lie, presenting a separate and more serious ground for bias than another motive already presented to the jury.
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Why it matters
This opinion reinforces that Florida trial courts have no discretion to exclude cross-examination going to a witness's bias or motive to fabricate, even when the underlying facts are inflammatory (here, child… — full analysis with a trial
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