Walker v. State
2012 Fla. App. LEXIS 685
| Fla. Dist. Ct. App. | 2012Background
- Walker was convicted of manslaughter, armed burglary of a dwelling with assault or battery, and armed robbery after a second trial.
- The key link to Walker came from Raymond’s identification of Walker from photographs after information Raymond received from unnamed individuals on the street.
- Raymond’s initial identification relied on a photopack after a delay; no physical evidence tied Walker to the crimes.
- A palm print from an unidentified third party was found, and Raymond’s and Elaine’s statements suggested an identification process without corroborating physical evidence.
- During the direct exam, Raymond testified to information from the streets naming the suspect; Yolanda later corroborated the tip.
- At trial, Walker challenged the reliability of the identification and the hearsay evidence regarding unidentified informants, leading to a post-trial appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether anonymous street information is admissible hearsay. | Walker. | State. | Inadmissible hearsay; requires reversal. |
Key Cases Cited
- Keen v. State, 775 So.2d 263 (Fla.2000) (prohibits anonymous tips used to establish guilt or sequence of events)
- Wilding v. State, 674 So.2d 114 (Fla.1996) (anonymous tip testimony can violate confrontation rights)
- Stokes v. State, 914 So.2d 514 (Fla.4th DCA 2005) (inadmissible testimony about information from non-testifying sources)
- Stribbling v. State, 778 So.2d 452 (Fla.4th DCA 2001) (anonymous information leading to identification deemed inadmissible)