Bearden v. State
62 So. 3d 656
| Fla. Dist. Ct. App. | 2011Background
- Bearden was convicted of second-degree murder and sentenced to life imprisonment; William Brown killed Skipper with a knife, and Bearden's role was contested.
- Bearden claimed the gas-station trip was a ruse to rob Skipper and that he did not participate in the killing; the State's witnesses placed Bearden in the car and linked William to the stabbing.
- Angela Tyler, a new witness, stated Ray Allen Brown admitted being in the car and involved in the killing, which could exonerate Bearden if admitted.
- The State disclosed Tyler’s statement; the defense sought to call Ray Allen to impeach him with Tyler’s proffered testimony, and then sought to admit Tyler’s testimony itself.
- The trial court excluded Tyler’s statements under Evidence Code, applying Chambers v. Mississippi four-part test, and denied recalling Ray Allen for impeachment.
- The court ultimately affirmed Bearden’s judgment and sentence, noting potential for postconviction claims but declining to address ineffective assistance on direct appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of Tyler’s statements under Chambers | Bearden | Bearden | Chambers test not met; statements unreliable |
| Whether Ray Allen could be recalled for impeachment | Bearden | Bearden | Defense cannot recall for impeachment absent Chambers admissibility |
Key Cases Cited
- Chambers v. Mississippi, 410 U.S. 284 (U.S. Supreme Court, 1973) (four-part test for hearsay declarations against penal interest with reliability focus)
- Curtis v. State, 876 So.2d 13 (Fla. 1st DCA, 2004) (impeachment evidence exception and reliability considerations in Curtis)
- Morton v. State, 689 So.2d 259 (Fla.1997) (impeachment of witnesses and limits on calling for sole impeachment purpose)
- Jones v. State, 709 So.2d 512 (Fla.1998) (considerations in assessing credibility and reliability of hearsay recipient)