Siegel v. State
68 So. 3d 281
| Fla. Dist. Ct. App. | 2011Background
- Siegel charged with knowingly using the internet to seduce a minor under Fla. Stat. 847.0135(3) (2002) over nine months in 2003.
- State sought to admit Williams Act similar-crimes evidence from Pennsylvania and St. Lucie County investigations.
- During jury selection, court disallowed defense peremptory strikes of two female jurors with gender-neutral reasons.
- Cross-examination about St. Lucie County defense tactics was allowed after Siegel testified the charges were dismissed.
- Siegel testified the ‘Monica’ chats were with adults and presented a ‘fantasy’ defense about imaginary online identities.
- Court reversed for a new trial due to peremptory-strike error and barred improper cross-examination and limited discovery ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court erred in denying peremptory strikes | Siegel | Siegel | Reversed for new trial; genuineness analysis required |
| Whether the court properly analyzed genuineness of gender-neutral strikes | Siegel | Siegel | Remand for new trial; analysis lacking |
| Whether cross-exam questioning about St. Lucie County defense opened the door | Siegel | Siegel | Reversed for new trial; opening-the-door ruling improper |
| Whether Siegel was entitled to inspect the Boynton Beach hard drive | Siegel | Siegel | Affirmed denial of full hard-drive discovery; no abuse found |
| Whether the court properly limited discovery under Fla. R. Crim. P. 3.220(f) | Siegel | Siegel | Affirmed; no materiality shown to compel broader production |
Key Cases Cited
- Melbourne v. State, 679 So.2d 759 (Fla.1996) (three-part peremptory-challenge framework; genuineness analysis guidance)
- Jones v. State, 787 So.2d 154 (Fla.4th DCA 2001) (genuineness analysis required when neutral reasons given; failure to analyze pretext)
- Fotopoulos v. State, 608 So.2d 784 (Fla.1992) (neutral reasons for strikes; reasons not applicable to others; pretext considerations)
- Cullen v. State, 920 So.2d 1155 (Fla.4th DCA 2006) (opening the door when testimony is misleading; undue expansion of cross-examination)
