Michael Roundtree v. State
145 So. 3d 963
| Fla. Dist. Ct. App. | 2014Background
- Roundtree was convicted of armed robbery and two counts of false imprisonment in the Florida Fourth DCA.
- Evidence included fingerprints on deodorants at the store matching Roundtree.
- An January 2011 police interrogation consisted mainly of the officer expressing guilt opinions; a portion mentioning his jail history was excluded.
- During interrogation the officer repeatedly accused Roundtree of the robbery; Roundtree denied it but the officer insisted on guilt.
- The jury heard most of the interrogation; defense presented wife testimony that Roundtree was home at the time.
- The appellate court held the trial court abused its discretion by admitting the interrogation and reversed/remanded for a new trial, noting potential curative limiting instructions but not applying them here.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of officer’s guilt opinions | Roundtree argues officer’s guilt opinions invaded the jury’s province. | State contends statements provide context and may be probative for interrogation strategy. | Interrogation should have been excluded; admission error. |
| Harmlessness of the error | The error was not harmless beyond a reasonable doubt. | The error could be harmless in light of other evidence. | Error not harmless beyond a reasonable doubt; reversed. |
| Potential cure by limiting instruction | Limiting instructions may obviate prejudice in some cases. | Instruction not applicable to cure the admitted statements here. | Acknowledges possible limiting-instruction remedy in similar cases, but reversal remains. |
Key Cases Cited
- State v. DiGuilio, 491 So. 2d 1129 (Fla. 1986) (harmless-error standard for reviewing trial court decisions)
- Jackson v. State, 107 So. 3d 328 (Fla. 2012) (officer’s repeated guilt opinions in interrogation generally inadmissible)
- Pausch v. State, 596 So. 2d 1216 (Fla. 2d DCA 1992) (limiting-instruction approach to police statements)
- Eugene v. State, 53 So. 3d 1104 (Fla. 4th DCA 2011) (example of jury-instruction language to limit jury reliance on interrogator’s statements)
- Hudson v. State, 992 So. 2d 96 (Fla. 2008) (trial-court evidentiary rulings reviewed for abuse of discretion)