Reaves v. State
The Fourth DCA reversed a defendant's plea-based conviction because the State failed to prove by competent, substantial evidence that statutory exceptions to the statute of limitations applied to a DNA 'cold hit' sexual battery prosecution. The State relied solely on a judicially-noticed court file, including the arrest affidavit, which the court held was inadmissible hearsay and thus insufficient to satisfy its burden. The court also rejected the State's argument that the dismissal issue was non-dispositive, deferring to the trial court's dispositive finding.
Key facts
- Defendant was charged with sexual battery based on a DNA 'cold hit' match in a case where the statute of limitations had potentially expired.
- The trial court granted defendant's motion to dismiss based on the statute of limitations and defendant entered a nolo contendere plea, preserving the dismissal issue for appeal.
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Why it matters
This decision is useful for defense counsel litigating statute-of-limitations challenges in delayed-prosecution or DNA cold-hit cases, confirming that the State cannot rely on hearsay contained in charging documents or… — full analysis with a trial
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