State v. Williams
The State sought certiorari review of a trial court order requiring disclosure of a confidential informant's identity in a drug-sale prosecution where the informant was the sole participant (other than the defendant) in each transaction. The Third District denied the petition, holding that under Roviaro and Zamora, disclosure is required when the defendant is charged with selling drugs directly to an informant who was the only other participant, and that the existence of audio-video recordings of the transactions did not constitute 'clearly established law' excusing disclosure absent controlling Florida precedent.
Key facts
- State sought certiorari review of trial court order requiring disclosure of a confidential informant's identity in a drug-sale prosecution where the informant was the sole other participant in each transaction with the defendant.
- The defendant was charged with selling or delivering drugs directly to a confidential informant; the State argued that audio-video recordings of the transactions made disclosure unnecessary.
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Why it matters
This opinion is useful for practitioners litigating confidential-informant disclosure motions in drug cases, reaffirming that the 'sole participant' rule from Roviaro/Zamora applies even where transactions are… — full analysis with a trial
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