ROYCE TEETS v. STATE OF FLORIDA, 19-2253

Defendant Royce Teets shot and killed his fiancée during an argument; he claimed the shooting was accidental and the rifle had a "hair trigger."
After the shooting Teets gave varying statements to 911 and police (initially saying they had been "messing with" the rifle; later admitting he racked the gun and thought it was empty).
Police recovered an AK-47, magazines, live rounds, a detached clip, and DNA consistent with Teets on the gun grip; forensic testing included a trigger-pull measurement.
At trial the State’s firearms expert testified the trigger pull was about 4.5 pounds (not a "hair trigger") and the court allowed each juror to handle a 4.5-pound demonstrative weight over defense objection.
Defense objected at trial that the trigger-pull results and demonstrative testing were undisclosed discovery material and moved for a Richardson hearing and for a mistrial; the trial court denied relief and the jury convicted Teets of second-degree murder.
On appeal Teets argued the trial court erred in failing to hold a Richardson hearing and in admitting the trigger-pull test and demonstrative aid; he also challenged denial of a mistrial. The Fourth DCA affirmed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Teets)	Held
Whether the trial court should have held a Richardson hearing and excluded or sanctioned undisclosed trigger-pull results/demonstrative aid	No discovery violation occurred: the Crime Lab report was produced; examiner notes (trigger-pull) are exempt from disclosure; Teets could have deposed the expert; any error was harmless	The trigger-pull evidence was effectively sprung on defense, prejudicing Teets’ accidental-discharge defense and requiring a Richardson inquiry and relief	No Richardson hearing required because no discovery violation: report was disclosed and examiner notes are exempt; admission harmless; no abuse of discretion
Whether the court erred in denying Teets’ motion for mistrial	No basis for mistrial; any procedural issue did not prejudice the defense	The undisclosed evidence and juror handling of the demonstrative weight warranted a mistrial	No merit to the mistrial claim; denial affirmed

Richardson v. State, 246 So. 2d 771 (Fla. 1971) (establishes trial-court Richardson inquiry when discovery violation is found)
Geralds v. State, 601 So. 2d 1157 (Fla. 1992) (crime-lab and analyst notes exempt from routine discovery)
Terry v. State, 668 So. 2d 954 (Fla. 1996) (reinforces that analysts' notes are generally not subject to disclosure)
Jules v. State, 178 So. 3d 475 (Fla. 4th DCA 2015) (discusses when Richardson inquiry is required)
Smith v. State, 283 So. 3d 817 (Fla. 4th DCA 2019) (trial court must find a discovery violation before Richardson factors are applied)
State v. Schopp, 653 So. 2d 1016 (Fla. 1995) (harmless-error standard for discovery violations)