Oquendo v. State
The Second District affirmed Oquendo's manslaughter conviction, holding that expert testimony on his PTSD was properly excluded as irrelevant to his self-defense claim because Florida's self-defense standard is objective, not subjective. The court distinguished PTSD evidence from battered-spouse syndrome evidence (admissible under Weiand/Hickson) and expressly certified conflict with the First District's contrary holding in State v. Mizell.
Key facts
- Oquendo was convicted of manslaughter in trial court after claiming self-defense.
- Oquendo sought to introduce expert testimony that he suffered from PTSD to support his self-defense claim, but the trial court excluded the evidence.
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Why it matters
This opinion creates an express district split on whether PTSD evidence is admissible to support a self-defense claim, squarely conflicting with the First District's Mizell decision and inviting Florida Supreme Court… — full analysis with a trial
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