Schofield v. State
67 So. 3d 1066
Fla. Dist. Ct. App.2011Background
- Schofield was convicted of first-degree murder in 1989 for the 1987 death of his wife Michelle.
- At trial, unidentified fingerprints found in Michelle’s car were used to support a defense that another person committed the crime.
- In 2004 the previously unidentified fingerprints were identified as Jeremy Scott, prompting Schofield to seek postconviction relief as newly discovered evidence.
- On remand, an evidentiary hearing was held; the postconviction court treated challenged evidence as admissible for analysis but later held it would not likely yield an acquittal.
- The court applied the Jones II standard for newly discovered evidence, focusing on whether the evidence could probably produce an acquittal at retrial.
- Schofield appeals the ruling affirming the postconviction court’s decision; the court affirms, holding the proffered evidence would not produce a reasonable doubt.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does the newly discovered fingerprint evidence likely yield acquittal? | Schofield argues it would. | State contends it would not. | Affirmed; not capable of producing acquittal under Jones II. |
| Are the additional prior-bad-acts evidence and related Scott data admissible to support a retrial claim? | Schofield contends it is admissible to prove weakness of the State’s case. | State argues such evidence is inadmissible character evidence and unrelated to retrial probability. | Not admissible; would not weaken the State’s case or create a reasonable doubt. |
| Is the appellate court bound by the postconviction court’s evidentiary rulings on admissibility? | Schofield asserts deference to those rulings. | State argues deference applies but incorrect rulings are reviewable de novo. | Appellate court reviews de novo the application of law to facts; not bound by postconviction court’s admissibility determinations if error. |
Key Cases Cited
- Jones v. State, 709 So.2d 512 (Fla.1998) (two-prong test for newly discovered evidence)
- Hitchcock v. State, 991 So.2d 337 (Fla.2008) (limits on admissibility of character or propensity evidence for impeachment)
- Jones v. State, 591 So.2d 911 (Fla.1991) (duty to weigh all admissible newly discovered evidence against trial record)
- Sims v. State, 754 So.2d 657 (Fla.2000) (admissibility of newly discovered evidence on retrial)
- Robinson v. State, 707 So.2d 688 (Fla.1998) (scope of newly discovered evidence review)
- Williams v. State, 110 So.2d 654 (Fla.1959) (fundamental rules on admissibility of prior acts and impeachment)
- Drake v. State, 400 So.2d 1217 (Fla.1981) (limitations on Williams-rule admissibility)
- Rivera v. State, 561 So.2d 536 (Fla.1990) (reverse Williams rule considerations)
- Fulton v. State, 335 So.2d 280 (Fla.1976) (arrests not resulting in conviction are inadmissible in general)
- Howard v. Risch, 959 So.2d 308 (Fla.2d DCA 2007) (impeachment limitations on detailing prior crimes)