JOHN GOODMAN v. STATE OF FLORIDA, 229 So. 3d 366

Background

Late-night two-vehicle crash: Goodman (driving a Bentley) T‑boned the victim; victim’s car went into a canal and the victim drowned later; victim’s fatality resulted from drowning, not initial collision.
Goodman left the scene, sought a phone, made a 911 call ~1:56 a.m., returned with deputies; exhibited signs of intoxication and was transported to hospital; blood drawn at ~3:59–4:00 a.m. showing BAC ≈ .177–.178 (retrograde to .207–.237 at crash).
At first trial the Bentley and expert testing (including ECM fault codes showing throttle desynchronization) were presented; conviction was later vacated due to juror misconduct and a retrial was ordered.
Before the second trial the State prematurely released the Bentley; it was later found refurbished in Texas, which limited further physical testing by Goodman’s expert.
Jury instructions were given on failure-to-render-aid enhancements; the court required actual knowledge of the accident (not the statutory standard “knew or should have known” in some respects) and expressly instructed that knowledge of injury or death was not required.
Court denied motion to dismiss for spoliation, denied suppression of blood test (exigent‑circumstances), jury convicted on DUI manslaughter with failure to render aid; court withheld adjudication on vehicular homicide (later vacated on double jeopardy grounds on appeal).

Issues

Issue	Plaintiff's Argument (Goodman)	Defendant's Argument (State)	Held
1) Did State’s premature release of the Bentley violate due process / require dismissal?	Bentley was constitutionally material; loss prevented defense expert from conducting physical tests that could exonerate Goodman.	Bentley was at most potentially useful; ECM data and prior tests already available; State did not act in bad faith and agreed not to call its expert.	Denied dismissal; evidence was not constitutionally material under Trombetta/Youngblood; no bad faith and comparable evidence existed.
2) Were jury instructions erroneous for failing to require knowledge of injury or death for failure‑to‑render‑aid enhancement?	Court should have required that Goodman knew the accident resulted in injury or death (actual knowledge).	Statutes require only that defendant knew or should have known of the crash; Legislature excluded knowledge of injury/death; instruction as given (requiring knowledge of accident but not injury/death) was proper.	No reversible error: statutes do not require knowledge of injury/death; instruction’s deviation (requiring actual knowledge of crash) favored defendant.
3) Was the warrantless blood draw a Fourth Amendment violation?	Blood draw was taken without a warrant and consent; McNeely controls—natural dissipation of alcohol alone doesn't always justify exigency.	Circumstances (time elapsed, discovery of body, investigatory needs, investigator’s testimony that obtaining a warrant would take ~2.5 hours) created exigent circumstances analogous to Schmerber.	Denied suppression: totality of circumstances established exigency; warrantless draw was reasonable under the Fourth Amendment.
4) Did conviction/sentence on both DUI manslaughter and vehicular homicide violate double jeopardy?	(Implicit) Both convictions arise from same act/victim; convicting on both is duplicative.	State requested to hold adjudication in abeyance to preserve sentencing if DUI conviction reversed.	Vacated vehicular homicide conviction on double jeopardy grounds (withholding adjudication counts as conviction for double jeopardy purposes).

Key Cases Cited

California v. Trombetta, 467 U.S. 479 (constitutional materiality test for lost evidence)
Arizona v. Youngblood, 488 U.S. 51 (bad‑faith requirement for lost potentially useful evidence)
Missouri v. McNeely, 569 U.S. 141 (exigency/warrant exception analysis for blood draws)
Schmerber v. California, 384 U.S. 757 (warrantless blood draw justified by exigent circumstances in crash/hospital context)
Patterson v. State, 199 So.3d 253 (Fla. 2016) (analogous spoliation/materiality analysis)
State v. Adkins, 96 So.3d 412 (Fla. 2012) (legislative power to set mens rea for statutes; due process limits)
State v. Dumas, 700 So.2d 1223 (Fla. 1997) (purpose of failure‑to‑render‑aid statutes to ensure prompt assistance)
State v. Mancuso, 652 So.2d 370 (Fla. 1995) (hit‑and‑run mens rea discussion)