Satyanand v. State, 147 So. 3d 662

Satyanand filed a petition for a writ of mandamus to compel a pretrial evidentiary hearing on his immunity-based motion to dismiss under section 776.032, Florida Statutes (2012).
Satyanand was charged with aggravated battery with great bodily harm and moved to dismiss on immunity grounds.
A hearing on the motion was scheduled but repeatedly continued due to defense requests and scheduling conflicts among the State, court, and defense.
The trial court, as trial date approached, stated it would address the motion during trial rather than at a pretrial evidentiary hearing.
Satyanand sought mandamus relief; the State conceded that a pretrial hearing is ordinarily required but argued Satyanand failed to show entitlement to mandamus relief and noted continuances were largely defense-requested.
Florida case law holding that a pretrial evidentiary hearing is required on 776.032 immunity claims supports granting the mandamus relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a pretrial evidentiary hearing is required on immunity under 776.032	Satyanand seeks mandamus to compel a pretrial hearing.	State notes continuances and defense scheduling; argues mandamus relief not shown.	Yes; mandamus relief granted requiring a pretrial hearing.

Dennis v. State, 51 So.3d 456 (Fla.2010) (pretrial evidentiary hearing required on 776.032 immunity)
Peterson v. State, 983 So.2d 27 (Fla.1st DCA 2008) (trial court must conduct pretrial immunity hearing)
Professional Roofing & Sales, Inc. v. Flemmings, 138 So.3d 524 (Fla.3d DCA 2014) (pretrial hearing appropriate for Stand Your Ground immunity)
Wonder v. State, 69 So.3d 371 (Fla.4th DCA 2011) (pretrial evidentiary hearing warranted on immunity claim per Dennis)
Legene v. State, 60 So.3d 1154 (Fla.5th DCA 2011) (mandamus relief to order hearing on immunity motion)
Martinez v. State, 44 So.3d 1219 (Fla.1st DCA 2010) (mandamus relief for pretrial immunity hearing)