Richard Kevin Kline v. State of Florida, 223 So. 3d 482

Appellant (Richard Kline) was convicted of second-degree murder and sentenced to life for the death of his wife; he appealed the denial of his motion for judgment of acquittal.
The State’s case was entirely circumstantial—no direct DNA or physical evidence tied Kline to the murder scene.
Evidence placed Kline living with the victim and as the last person to have contact with her on Oct. 3, 2014 (Skype session ended 1:54 a.m.; Kline left home ~8:30 a.m.).
GPS from the financed vehicle tracked the car’s movements from the home to Tennessee; the car was packed with clothes, golf clubs, food, money, and much of the victim’s jewelry.
Kline wrote an incriminating letter to his ex-wife during a Georgia motel stop expressing hatred for his wife and stating plans to leave; he later purchased a new cell phone and emptied joint bank accounts.
No evidence of forced entry or an identifiable third-party suspect; the State presented a timeline and physical evidence (packed car, GPS) the jury found inconsistent with Kline’s hypothesis of suicide and innocence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of circumstantial evidence to deny judgment of acquittal	State: Circumstantial evidence (timeline, GPS, packed car, letter) is sufficient and inconsistent with any reasonable hypothesis of innocence	Kline: Evidence is wholly circumstantial and consistent with his innocence (suicide plan, no direct physical evidence)	Affirmed: Evidence, when viewed for the State, was sufficient to exclude reasonable hypothesis of innocence and support conviction
Presence of alternative suspects / need to exclude every hypothesis	State: No evidence of a third-party motive; timeline and tracing of vehicle point solely to Kline	Kline: Lack of direct physical ties and possible alternative explanations (no forced entry, equivocal physical evidence)	Affirmed: Court found no credible third-party suspect and that State need not disprove every remote hypothesis—only show inconsistency with reasonable hypothesis of innocence

Pagan v. State, 830 So. 2d 792 (Fla. 2002) (standard of appellate review and circumstantial-evidence principles)
Twilegar v. State, 42 So. 3d 177 (Fla. 2010) (circumstantial-evidence rule requires exclusion of reasonable hypotheses of innocence)
Lindsey v. State, 14 So. 3d 211 (Fla. 2009) (evidence must establish guilt to a reasonable and moral certainty)
Dausch v. State, 141 So. 3d 513 (Fla. 2014) (clarifying circumstantial-evidence requirements)
Ballard v. State, 923 So. 2d 475 (Fla. 2006) (circumstantial evidence must exclude reasonable hypotheses of innocence)
Durousseau v. State, 55 So. 3d 543 (Fla. 2010) (when evidence contradicts defendant’s theory, that is for the jury)
State v. Law, 559 So. 2d 187 (Fla. 1989) (State need only introduce competent evidence inconsistent with defendant’s theory)
Floyd v. State, 850 So. 2d 383 (Fla. 2002) (circumstantial-evidence standard discussion)
Cannon v. State, 180 So. 3d 1023 (Fla. 2015) (rejecting reasonable-hypothesis of innocence)
Ferguson v. State, 417 So. 2d 631 (Fla. 1982) (examples of rejecting unreasonable hypotheses)
Toole v. State, 472 So. 2d 1174 (Fla. 1985) (appellate deference to jury verdict supported by substantial competent evidence)