RUBEN ISRAEL RENTAS v. STATE OF FLORIDA, 237 So. 3d 368

Ruben Israel Rentas convicted of multiple sexual offenses involving a minor; sentenced to life plus consecutive terms; appealed.
Defense theory: Rentas gave a false/confession; during voir dire defense asked jurors whether people confess to crimes they did not commit.
Three prospective jurors (Juror 1-5, Juror 3-7, Juror 4-3) expressed serious skepticism that an innocent person would falsely confess to crimes of this nature; defense moved to strike them for cause; trial court granted only one strike and denied challenges to Jurors 1-5 and 3-7.
During deliberations, the jury requested playback of the minor victim’s testimony; the court replayed the first 20 minutes of direct examination only, over defense objection requesting corresponding cross-examination be replayed as well.
Jury found Rentas guilty on all counts; on appeal the Fourth District reversed, finding errors in denying cause strikes and in permitting a partial read-back without relevant cross-examination, and remanded for a new trial.

Issue	Rentas' Argument	State's Argument	Held
Whether the trial court erred by denying for-cause strikes for jurors who expressed doubt that an innocent person would confess to serious sexual crimes	Jurors 1-5 and 3-7 expressed preconceived beliefs that innocent people would not falsely confess to serious crimes, creating reasonable doubt as to impartiality and requiring strikes for cause	Expressions of skepticism about false confessions do not require exclusion if jurors say they can be fair and will follow the evidence; such beliefs are permissible if rehabilitated	Reversed: trial court abused discretion by denying strikes for Jurors 1-5 and 3-7 because their statements created reasonable doubt as to impartiality
Whether replaying only the first 20 minutes of the victim’s direct testimony (without associated cross-examination) was reversible error	Partial playback emphasized the State’s version and omitted cross-examination that could undermine those portions; court should have provided corresponding cross-examination or at least inquired further into what the jury wanted	Trial court has broad discretion to read back testimony; jury requested only a portion of direct testimony and the court accommodated that request	Reversed as to all counts: partial read-back without related cross-examination was potentially misleading and harmful, and the State did not show the error harmless beyond a reasonable doubt as to the under-12 molestation charge

Ranglin v. State, 55 So. 3d 744 (Fla. 4th DCA 2011) (standard for abuse of discretion on cause challenge)
Carratelli v. State, 961 So. 2d 312 (Fla. 2007) (juror must be able to render verdict solely on evidence and law)
Montozzi v. State, 633 So. 2d 563 (Fla. 4th DCA 1994) (equivocal promises of impartiality inadequate; reversible error when bias persists)
Mullins v. State, 78 So. 3d 704 (Fla. 4th DCA 2012) (partial read-back of direct testimony without cross-examination can unduly emphasize State’s version)
Gormady v. State, 185 So. 3d 547 (Fla. 2d DCA 2016) (following Mullins; partial read-back that omits cross undermines fairness)
Ventura v. State, 29 So. 3d 1086 (Fla. 2010) (harmless-error test requires State to prove error did not contribute to verdict)
State v. DiGuilio, 491 So. 2d 1129 (Fla. 1986) (standard for harmless error review)