Statler v. State
The Florida Supreme Court held that section 794.011(5)(b), Florida's basic sexual battery statute, requires the State to prove only that the complainant did not in fact consent—not that the defendant knew or should have known the complainant did not consent. The Court held sexual battery is a general-intent crime rooted in the common law of rape, and that reading the statute this way does not violate due process under the Florida or U.S. Constitutions, approving the First District's affirmance of Statler's conviction.
Key facts
- Defendant Statler was convicted of sexual battery under Florida Statute section 794.011(5)(b) in the trial court, and the First District Court of Appeal affirmed the conviction.
- Statler challenged the constitutionality of the sexual battery statute, arguing it violated due process by not requiring the State to prove he knew or should have known the complainant did not consent.
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Why it matters
This is a landmark Florida Supreme Court ruling resolving a long-simmering constitutional challenge to the state's core sexual battery statute and definitively confirming that sexual battery is a general-intent crime… — full analysis with a trial
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