Woodruff v. State, 208 So. 3d 1265

Defendant Michael Woodruff was convicted of one count of lewd or lascivious molestation of a victim under 12; acquitted of related counts and a sexual battery charge. Sentence: 25 years imprisonment plus lifetime supervised probation with electronic monitoring.
Woodruff raised four issues on direct appeal: two evidentiary rulings (exclusion of evidence that the victim was the product of a sexual battery; exclusion of evidence that the victim previously fabricated a pregnancy), denial of a new trial based on a post-trial juror interview, and ineffective assistance of counsel.
The trial court excluded the proffered evidence under rules governing relevance and 90.403 balancing (unfair prejudice, confusion, misleading the jury). The pregnancy rumor involved unrelated third parties years after the alleged offenses.
After verdict, a juror told an interviewer he realized at verdict reading he did not believe the State had proven the charge, but acknowledged he had voted guilty during deliberations and affirmed the verdict when polled in court.
The trial court denied a new trial motion. Woodruff sought to raise ineffective assistance on direct appeal but the court declined to address it, noting such claims generally must be raised in postconviction proceedings unless apparent on the record.

Issue	Woodruff's Argument	State's Argument	Held
Exclusion of evidence that victim was product of sexual battery	Evidence would impeach or bear on victim credibility/relevance to charges	Evidence irrelevant and prejudicial; probative value outweighed by unfair prejudice/confusion	Affirmed; exclusion proper under balancing rule (90.403)
Exclusion of evidence that victim fabricated pregnancy	Shows victim's propensity to fabricate and impeaches credibility	Rumor unrelated to defendant, concerned third parties, occurred years later; minimal probative value and prejudicial	Affirmed; excluded as cumulative/remote and more prejudicial than probative
Denial of new trial based on juror's post-trial interview	Juror admission that he later believed State didn't prove guilt warrants new trial	Juror affirmed verdict during polling; statements concern juror’s internal deliberative thought (inheres in verdict) and are not admissible to impeach verdict	Affirmed; juror testimony about internal beliefs inadmissible to attack verdict (Marks/Devoney)
Ineffective assistance of counsel raised on direct appeal	Trial counsel was ineffective (various unspecified claims)	Such claims should be litigated in postconviction proceedings unless the record conclusively shows ineffectiveness	Not reached on merits; claim must be raised via postconviction motion (direct-appeal bar)

Stephens v. State, 787 So. 2d 747 (Fla. 2001) (abuse of discretion standard for new-trial review)
Alston v. State, 723 So. 2d 148 (Fla. 1998) (abuse of discretion standard for admissibility rulings)
Prieto v. State, 439 So. 2d 288 (Fla. 3d DCA 1983) (abuse of discretion review for new-trial rulings)
McLean v. State, 934 So. 2d 1248 (Fla. 2006) (application of section 90.403 balancing)
Marks v. State Road Dep’t, 69 So. 2d 771 (Fla. 1954) (limitations on juror affidavits to impeach verdict)
Devoney v. State, 717 So. 2d 501 (Fla. 1998) (juror testimony barred when matter inheres in verdict)
Mitchell v. State, 527 So. 2d 179 (Fla. 1988) (juror affidavit rules and verdict challenges)
Bruno v. State, 807 So. 2d 55 (Fla. 2001) (ineffective-assistance claims generally not cognizable on direct appeal)
Gore v. State, 784 So. 2d 418 (Fla. 2001) (exception where ineffectiveness is apparent on face of record)
Rivera v. State, 193 So. 3d 1033 (Fla. 3d DCA 2016) (application of direct-appeal bar for ineffective-assistance claims)
Carlisle v. State, 137 So. 3d 479 (Fla. 4th DCA 2014) (distinguished by court on facts regarding impeachment evidence)