Lawrence William Patterson v. State of Florida
153 So. 3d 307
| Fla. Dist. Ct. App. | 2014Background
- Patterson was convicted of multiple arson and fraud counts related to a house fire and a vehicle fire, including arson, arson resulting in injury to a firefighter, and insurance-fraud offenses.
- The key physical evidence in dispute was a truck allegedly used to start the fires; the truck was destroyed by the auto insurer five months before arrest, after investigators had examined it.
- Patterson moved to dismiss or exclude expert testimony relying on the destroyed truck; trial court denied the motion.
- State Fire Marshal and insurers had collected evidence and photographed the scene; Patterson’s expert relied on approximately 300 photographs.
- Patterson argued destruction of the truck violated due process under Brady/Youngblood; the court analyzed whether bad faith or prejudice required dismissal or exclusion.
- The court ultimately affirmed all convictions, ruling no due-process violation and that the trial remained fundamentally fair despite the truck’s unavailability.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether destruction of the truck violated due process | Patterson claims destroyed truck was critical evidence | State maintains no bad faith; no prejudice | No due-process violation; convictions affirmed |
| Whether the trial court should have excluded expert testimony due to missing truck | Destruction deprived Patterson of opportunity to challenge experts | Photographs and alternative evidence sufficed; Cope’s testimony supported conviction | Trial not fundamentally unfair; no exclusion required |
| Whether there is a double jeopardy issue | Convictions based on overlapping acts | Convictions based on distinct acts or statutory intent | No double jeopardy violation; affirmed on separate/intent basis |
Key Cases Cited
- Farrell v. State, 317 So. 2d 144 (Fla. 1st DCA 1975) (destruction of recording violated Brady when undisputed material)
- Brady v. Maryland, 373 U.S. 83 (U.S. 1963) (exculpatory evidence suppression violates due process)
- Arizona v. Youngblood, 488 U.S. 51 (U.S. 1988) (bad faith required for failure to preserve potentially useful evidence)
- Lancaster v. State, 457 So. 2d 506 (Fla. 4th DCA 1984) (unfair to allow state to use unchallengeable evidence when truck was negligently disposed)
- Guzman v. State, 868 So. 2d 498 (Fla. 2003) (Brady prejudice standard applied; materiality depends on likelihood of different outcome)
- Cardona v. State, 826 So. 2d 968 (Fla. 2002) (Brady materiality and discovery standards applied in Florida)
- State v. Ritter, 448 So. 2d 512 (Fla. 5th DCA 1984) (reflexive limitations on expert testimony when evidence destroyed)
- Lancaster ; Stipp v. State, 371 So. 2d 712 (Fla. 4th DCA 1979) (precedent on unfairness when evidence mishandled)
- Blockburger v. United States, 284 U.S. 299 (U.S. 1932) (each offense requires proof of a fact the other does not)
- Williams v. State, 90 So. 3d 931 (Fla. 1st DCA 2012) (partial framework for multiple conviction justification)