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Siegel v. State
68 So. 3d 281
| Fla. Dist. Ct. App. | 2011
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Background

  • 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)
Read the full case

Case Details

Case Name: Siegel v. State
Court Name: District Court of Appeal of Florida
Date Published: Jul 27, 2011
Citation: 68 So. 3d 281
Docket Number: No. 4D08-1524
Court Abbreviation: Fla. Dist. Ct. App.