Ramiro Ibarra challenges his judgment and sentences for trafficking in cocaine and conspiracy to traffic in cocaine. Although he asserts two grounds on appeal that he contends require a new trial, we address only his argument that the trial court reversibly erred when it allowed the State to impeach him with a previously undisclosed statement without first conducting a Richardson
At trial, Ibarra, who claimed he was entrapped, testified in his own defense. After he testified, the State announced its intention to call a police detective as a rebuttal witness. The State indicated the detective would testify about an oral statement Ibarra made to the detective that was contrary to Ibarra’s trial testimony. The State had not previously disclosed the content of the statement as required by Florida Rule of Criminal Procedure 3.220(b)(1)(C). Defense counsel
The standard for determining whether reversal is required for failing to conduct a Richardson hearing is hannless error. State v. Schopp,
Reversed and remanded for a new trial.
Notes
. See Richardson v. State,
