From Casetext: Smarter Legal Research

Servis v. State

District Court of Appeal of Florida, Fifth District
Oct 26, 2001
802 So. 2d 359 (Fla. Dist. Ct. App. 2001)

Summary

refusing to find error harmless because there was no way to determine the theory upon which the jury relied in reaching its verdict

Summary of this case from Cardenas v. State

Opinion

Case No. 5D00-2957

Opinion filed October 26, 2001

Appeal from the Circuit Court for Orange County, Dorothy J. Russell, Judge.

James B. Gibson, Public Defender, and Barbara C. Davis, Assistant Public Defender, Daytona Beach, for Appellant.

Robert A. Butterworth, Attorney General, Tallahassee, and Denise O. Simpson, Assistant Attorney General, Daytona Beach, for Appellee.


Dennis Wayne Servis appeals his conviction for DUI manslaughter pursuant to section 316.193(3)(a)(b)(c)(3), Florida Statutes (1999). He was convicted after a trial in which instructions were given to the jury over his objection regarding statutory presumptions of impairment pursuant to section 316. 1934(2), Florida Statutes (1999).

We must vacate the judgment of guilt and sentence because the Florida Supreme Court in State v. Miles, 732 So.2d 350 (Fla. 1st DCA), rev. granted, 740 So.2d 529 (Fla. 1999), approved in part, quashed in part, 775 So.2d 950 (Fla. 2000), held that Florida Administrative Code Rule 11D-8.012, fails to adequately provide for the preservation of blood samples taken for blood-alcohol analysis. Therefore, the impairment presumptions associated with the implied consent statutes are not available to the State.

Rule 11D-8012 was subsequently revised on July 29, 2001 to prescribe specific procedures for the collection and preservation of the blood sample.

Fla. Stat. §§ 316. 1932 — 316. 1934 (1999).

The State argues that the instructions on statutory presumption given to the jury were harmless error because of the overwhelming evidence of guilt and because the instructions allowed the jury to find Servis guilty either under a theory of being impaired without the statutory presumptions or that he had a blood-alcohol level of .08 or higher. Unfortunately, however, there is no way of analyzing the jury's verdict to determine the theory upon which it relied in rendering its verdict, and if it relied upon the statutory presumptions it was error under Miles.

We vacate the judgment and sentence and remand for a new trial.

JUDGMENT AND SENTENCE VACATED; REMANDED.

THOMPSON, C.J., and PLEUS, J., concur.


Summaries of

Servis v. State

District Court of Appeal of Florida, Fifth District
Oct 26, 2001
802 So. 2d 359 (Fla. Dist. Ct. App. 2001)

refusing to find error harmless because there was no way to determine the theory upon which the jury relied in reaching its verdict

Summary of this case from Cardenas v. State

In Servis v. State, 802 So.2d 359 (Fla. 5th DCA 2001), we held that the harmless error rule cannot apply in such cases because "there is no way of analyzing the jury's verdict to determine the theory upon which it relied in rendering its verdict."

Summary of this case from Bonine v. State
Case details for

Servis v. State

Case Details

Full title:DENNIS WAYNE SERVIS, Appellant, v. STATE OF FLORIDA, Appellee

Court:District Court of Appeal of Florida, Fifth District

Date published: Oct 26, 2001

Citations

802 So. 2d 359 (Fla. Dist. Ct. App. 2001)

Citing Cases

Wilson v. State

The trial court denied relief, correctly finding that both grounds had been raised on direct appeal. The…

Bonine v. State

In similar cases, we have recently rejected the state's request to find such error to be harmless. Bass v.…