Corona v. State
64 So. 3d 1232
| Fla. | 2011Background
- Corona was convicted of capital sexual battery of his eleven-year-old daughter after hearsay statements were admitted; the primary trial evidence consisted of A.C.'s statements via Deputy Avilas and Corona's statements via Chicago/Illinois officers.
- A.C. and Victoria were initially cooperative but Victoria refused to testify; the State could not compel their attendance.
- A.C.'s statements were ruled admissible at a suppression hearing over defense objections.
- Crawford v. Washington raised the issue that testimonial statements require prior cross-examination; the Fifth District held a discovery deposition satisfied this requirement.
- Lopez and Blanton later held that discovery depositions do not constitute a prior opportunity to cross-examine; this affected preservation and admissibility analyses.
- The Florida Supreme Court granted review to resolve whether a pretrial discovery deposition can satisfy Crawford’s cross-examination requirement and whether the confrontation issue was preserved.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a discovery deposition satisfies Crawford’s cross-examination requirement | Corona argues deposition suffices under Crawford | State contends deposition is not a true opportunity to cross-examine | Disproven; deposition does not satisfy Crawford |
| Whether Corona properly preserved the Crawford issue for appeal | Corona preserved by objection to A.C.'s statements | Preservation failed under prior Florida law | Preserved; confrontation error review applicable |
| Whether the confrontation violation was harmless error | Admission of A.C.'s statements prejudiced Corona | Error was harmless beyond a reasonable doubt | Harmful error; requires new trial |
Key Cases Cited
- Crawford v. Washington, 541 U.S. 36 (U.S. 2004) (testimonial statements require confrontation unless non-testimonial)
- Davis v. Washington, 547 U.S. 813 (U.S. 2006) (clarified distinction for statements during emergencies)
- Lopez v. State, 974 So.2d 340 (Fla. 2008) (discovery deposition does not satisfy Crawford cross-examination)
- Blanton v. State, 978 So.2d 149 (Fla. 2008) (reaffirmed Lopez; disapproved Blanton (Fla. 5th DCA) reasoning)
- State v. Contreras, 979 So.2d 896 (Fla. 2008) (harmless error framework for preserved Confrontation Clause claims)