From Casetext: Smarter Legal Research

Sadler v. State

District Court of Appeal of Florida, Fifth District
Jul 16, 1987
509 So. 2d 1139 (Fla. Dist. Ct. App. 1987)

Summary

precluding defense from proffering rebuttal testimony violates substantive due process and fair play, so case remanded for new trial

Summary of this case from Lillyman v. Dept. of Hwy. Safety

Opinion

No. 86-1968.

June 11, 1987. Rehearing Denied July 16, 1987.

Appeal from the Circuit Court for Hernando County, L.R. Huffstetler, Jr., J.

James B. Gibson, Public Defender, and Kenneth Witts, Asst. Public Defender, Daytona Beach, for appellant.

Robert A. Butterworth, Atty. Gen., Tallahassee, and W. Brian Bayly, Asst. Atty. Gen., Daytona Beach, for appellee.


This case is directly controlled by our prior opinion in Deel v. State, 481 So.2d 15 (Fla. 5th DCA 1985), review denied, 488 So.2d 831 (Fla. 1986). See also, Baeza v. State, 489 So.2d 36 (Fla. 4th DCA), review denied, 496 So.2d 142 (Fla. 1986). Here, as in Deel, the prosecution introduced expert medical testimony indicating that the hymen of the minor victim had been ruptured by sexual activity. The prosecution then successfully objected to proffered defense evidence which indicated that the injury (rupture) could have been caused by earlier sexual activity with a person other than the defendant. The exclusion of such rebuttal evidence contravenes both section 794.022(2), Florida Statutes (1985) and substantive due process of law, i.e., fair play.

REVERSED AND REMANDED FOR NEW TRIAL.

UPCHURCH, C.J., and SHARP, J., concur.


Summaries of

Sadler v. State

District Court of Appeal of Florida, Fifth District
Jul 16, 1987
509 So. 2d 1139 (Fla. Dist. Ct. App. 1987)

precluding defense from proffering rebuttal testimony violates substantive due process and fair play, so case remanded for new trial

Summary of this case from Lillyman v. Dept. of Hwy. Safety
Case details for

Sadler v. State

Case Details

Full title:ROBERT HENRY SADLER, APPELLANT, v. STATE OF FLORIDA, APPELLEE

Court:District Court of Appeal of Florida, Fifth District

Date published: Jul 16, 1987

Citations

509 So. 2d 1139 (Fla. Dist. Ct. App. 1987)

Citing Cases

Skipper v. State

Since the state chose to introduce this evidence, the defendant was entitled to present evidence that the…

McGriff v. State

Evidence of a victim's prior sexual encounters with others is admissible in a prosecution for sexual battery…