Celeste Chambers v. State of Florida, 200 So. 3d 242

Chambers, Revis, and Clark entered a fenced area behind a Goodwill warehouse and removed used fencing materials leaning against the building; Chambers was recorded and later charged with grand theft and trespass.
Goodwill witnesses said the fencing was used but "in good shape" and would have been reused; a Goodwill manager testified (without hearsay objection) that Home Depot replacement cost would be about $430.
Revis testified for the State under use immunity, identified participants on surveillance video, and on cross said she believed she had permission and thought the fence was trash.
On redirect, Revis stated she overheard Chambers’s boyfriend (a Goodwill supervisor) tell them they could "help [themselves]" and then volunteered that she and Clark had entered the warehouse and taken additional items (and that Chambers did not enter the warehouse but hurt her foot on a semi).
The trial court denied defense recross after this new redirect material, refused to require Revis to remain for the defense (citing immunity issues), and denied Chambers’s motion for judgment of acquittal on grand theft based on the State’s valuation evidence.
Chambers appealed, arguing insufficient evidence to prove value for grand theft and violation of her Sixth Amendment confrontation right by being denied recross on new redirect matters.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of value evidence for grand theft	State: replacement-cost evidence (Home Depot new fencing price) supports value ≥ $300	Chambers: evidence showed materials were used and weathered; new-item cost is not replacement value for used items	Reverse grand-theft conviction; evidence insufficient—at most petit theft
Confrontation Clause / denial of recross	State: redirect testimony was proper and did not require recross; no prejudice shown	Chambers: redirect introduced new material (entry into warehouse, other stolen items, Chambers’ presence on semi) and defense was denied opportunity to cross; harmed ability to contest culpability	Reversed and remanded for new trial on trespass and petit theft; denial of recross violated Sixth Amendment and was not harmless

Perez v. State, 187 So. 3d 1279 (Fla. 1st DCA 2016) (standard for reviewing judgment of acquittal)
Burns v. State, 132 So. 3d 1238 (Fla. 1st DCA 2014) (judgment of acquittal standard)
S.M.M. v. State, 569 So. 2d 1339 (Fla. 1st DCA 1990) (prosecution must prove value beyond a reasonable doubt)
Newland v. State, 117 So. 3d 482 (Fla. 2d DCA 2013) (replacement value requires like, similarly used property; new-item cost insufficient for used property)
McDuffie v. State, 970 So. 2d 312 (Fla. 2007) (defendant has absolute right to full and fair cross-examination)
Kelly v. State, 842 So. 2d 223 (Fla. 1st DCA 2003) (new matters developed on redirect require recross to protect confrontation rights)
Bordelon v. State, 908 So. 2d 543 (Fla. 1st DCA 2005) (recross required when redirect develops new material)