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State v. Betts

District Court of Appeal of Florida, Fifth District
Sep 8, 1995
659 So. 2d 1137 (Fla. Dist. Ct. App. 1995)

Opinion

No. 93-2936.

August 4, 1995. Rehearing Denied September 8, 1995.

9.160 Appeal from the County Court for Seminole County; Uriel Blount, Jr., Senior Judge.

Robert A. Butterworth, Atty. Gen., Tallahassee and Kristen L. Davenport, Asst. Atty. Gen., Daytona Beach, for appellant.

Hala A. Sandridge of Fowler, White, Gillen, Boggs, Villareal Banker, P.A., Tampa, for appellee.


We accepted jurisdiction of this cause in order to answer a certified question. Having more fully reviewed the record, however, we find the question certified was based on an invalid premise. We therefore modify the question to read as follows.

IF THERE IS AN ESTABLISHED POLICE POLICY OF VIDEOTAPING FIELD SOBRIETY TESTS, IS IT A VIOLATION OF DEFENDANT'S RIGHTS IF NO TAPE IS PRODUCED BECAUSE OF THE MECHANICAL FAILURE OF THE VIDEO CAMERA?

We answer this question in the negative.

We reverse the trial court because we find that Betts' due process rights were not violated. The officer attempted to videotape the roadside sobriety test but the camera malfunctioned. No tape was created; therefore, there was no tape to preserve. State v. Powers, 555 So.2d 888 (Fla. 2d DCA 1990), rev. denied, 563 So.2d 633 (Fla. 1990), is not implicated in this case because the failure to produce a tape was not an intentional policy decision.

The failure of a video camera to operate, without more, does not constitute a due process violation of defendant's rights. If the officer had intentionally caused the malfunction in order to avoid the department's policy of videotaping, an issue not before us, a different result might be required.

REVERSED and REMANDED.

W. SHARP and THOMPSON, JJ., concur.


Summaries of

State v. Betts

District Court of Appeal of Florida, Fifth District
Sep 8, 1995
659 So. 2d 1137 (Fla. Dist. Ct. App. 1995)
Case details for

State v. Betts

Case Details

Full title:STATE OF FLORIDA, APPELLANT, v. JAMES ROBERT BETTS, APPELLEE

Court:District Court of Appeal of Florida, Fifth District

Date published: Sep 8, 1995

Citations

659 So. 2d 1137 (Fla. Dist. Ct. App. 1995)

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