Martin v. State
110 So. 3d 936
| Fla. Dist. Ct. App. | 2013Background
- Appellant Martin was convicted of aggravated assault on a law enforcement officer and received a 20-year mandatory minimum sentence.
- Deputies responded to Martin’s home after welfare check; Martin threatened them and loaded a shotgun in their presence, then fired.
- Defense theory was insanity; Dr. Benson testified delirium could cause self-protective beliefs; Dr. Larson testified to paranoid delusions and self-defense firing.
- Trial court restricted further self-defense testimony and refused to give a self-defense jury instruction, while giving an insanity instruction.
- Appellant argued exclusion of self-defense evidence and lack of self-defense instruction violated his rights; the appellate court agreed.
- The court reversed and remanded for a new trial, with additional note affirming a separate evidentiary/jury instruction issue.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admission of self-defense evidence | Martin argues self-defense evidence should have been admitted. | State contends insanity defense renders self-defense evidence irrelevant. | Trial court erred in excluding self-defense evidence. |
| Jury instruction on self-defense | Martin sought a self-defense instruction supported by evidence. | State contends no instruction required once self-defense not raised. | Trial court erred by not giving self-defense instruction. |
Key Cases Cited
- Washington v. State, 737 So.2d 1208 (Fla. 1st DCA 1999) (defendant's right to present evidence and defense)
- Rivera v. State, 561 So.2d 536 (Fla. 1990) (evidence tending to create reasonable doubt admissible)
- Langston v. State, 789 So.2d 1024 (Fla. 1st DCA 2001) (instruction necessary if evidence supports theory)
- McCray v. State, 919 So.2d 647 (Fla. 1st DCA 2006) (trial court's evidentiary discretion review)
- Goode v. State, 856 So.2d 1101 (Fla. 1st DCA 2003) (standard for self-defense instruction)