Young v. State
The Sixth DCA affirmed the denial of a motion to suppress but reversed a drug trafficking conviction because the trial court failed to conduct a Richardson hearing after learning of an undisclosed statement by the defendant about becoming an informant. The court held the State failed to meet its heavy burden to show the discovery violation was harmless, since the statement undermined the defense's trial strategy of denying ownership of the drugs.
Key facts
- Young was charged with drug trafficking; the trial court denied his motion to suppress but convicted him after trial.
- During trial, the court learned of an undisclosed statement by Young about becoming an informant that the State had not formally disclosed in writing.
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Why it matters
This opinion provides a detailed, practitioner-useful reaffirmation of Richardson hearing requirements, including that prior disclosure at an earlier hearing (e.g., a suppression hearing) does not excuse the State's… — full analysis with a trial
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