Brown v. State, 227 So. 3d 185

Defendant Johnnie Allen Brown, III was convicted by a jury of felony battery (second or subsequent offense) after a January 6, 2016 incident with a former romantic partner and sentenced as a habitual felony offender to ten years.
The victim testified Brown jumped on and hit her three times; she denied carrying a knife or razor.
Brown admitted striking the victim but claimed self-defense, testifying the victim grabbed his belongings, brandished an X-Acto knife, and threatened him, causing him to fear for his safety.
On direct, defense counsel sought to elicit Brown's knowledge of the victim's reputation for violence and specific prior violent acts to show the reasonableness of his apprehension; the prosecutor objected as an improper character attack.
The trial court excluded the proffered reputation and specific-act testimony as character evidence and as irrelevant because Brown already testified about the immediate threat; the jury convicted and Brown appealed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Brown)	Held
Admissibility of victim's reputation evidence to support self-defense	Evidence is impermissible character attack and irrelevant; Brown already showed threat	Reputation is admissible to show victim's propensity for violence and corroborate defendant's fear	Exclusion was error — reputation evidence may be admitted to show propensity and corroborate self-defense when predicate shown
Admissibility of victim's specific prior acts to show reasonableness of defendant's apprehension	Specific-act evidence is improper character evidence and unnecessary given the overt act (knife)	Specific acts are admissible to prove reasonableness of defendant's apprehension when defendant knew of them and an overt act occurred	Exclusion was error — specific-act evidence admissible to show reasonableness where an overt act and defendant's knowledge are shown
Harmlessness of erroneous exclusion	Any error was harmless because other testimony established self-defense facts	Exclusion deprived Brown of important corroborating evidence in a he-said/she-said case	Error was not harmless; reversal and new trial required

Smith v. State, 661 So. 2d 358 (Fla. 1st DCA 1995) (reputation evidence admissible to show propensity; specific acts admissible to show reasonableness of defendant's fear)
Grace v. State, 832 So. 2d 224 (Fla. 2d DCA 2002) (defendant must know specific prior acts; reputation evidence may corroborate self-defense testimony)
Mohler v. State, 165 So. 3d 773 (Fla. 2d DCA 2015) (excluding competent evidence supporting sole self-defense claim may be prejudicial error)
Ray v. State, 755 So. 2d 604 (Fla. 2000) (admission of evidence reviewed for abuse of discretion)
State v. DiGuilio, 491 So. 2d 1129 (Fla. 1986) (prosecution must show no reasonable possibility that error contributed to conviction for harmless-error affirmance)