T.M. v. State
In a juvenile delinquency case, the Second DCA reversed a burglary adjudication because the trial court failed to hold a Richardson hearing after the defense objected that the State did not properly disclose the officer who obtained the child's confession. The court held that merely listing an officer as a general witness does not satisfy the discovery rule's requirement to separately identify witnesses to a defendant's statement, and the record was insufficient to find the error harmless.
Key facts
- T.M., a child, was adjudicated delinquent of burglary in the trial court based largely on a confession obtained by a police officer.
- The State listed the officer as a general witness but failed to separately identify the officer as a witness present when T.M.'s statement was taken, in violation of Florida Rule of Juvenile Procedure 8.060(a)(2)(A)(i)c.
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Why it matters
This opinion reinforces that Florida's juvenile discovery rule (materially identical to Rule 3.220 in criminal cases) requires specific identification of witnesses to a defendant's statements, not just general witness… — full analysis with a trial
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