L. J. E. AND T. A. E., MINORS, APPELLANTS,
v.
STATE OF FLORIDA, APPELLEE
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Two teenage sisters were adjudicated delinquent in juvenile court for obstructing police officers and committing battery upon them. The appellate court reversed, finding the evidence insufficient to prove guilt beyond a reasonable doubt where the officer was unidentified, in civilian clothes, and appeared to be attacking the girls' father without explanation.
The evidence was insufficient as a matter of law to establish guilt beyond a reasonable doubt. The appellants' adjudication of delinquency was reversed because, given the peculiar facts—particularly the officer's complete lack of identification and the ambiguous circumstances—the state failed to prove the essential elements of the offenses charged.
[1] Evidence is insufficient to sustain a finding of guilt if it does not establish guilt beyond and to the exclusion of every reasonable doubt.
[2] A police officer's failure to identify himself as law enforcement may negate the elements of obstructing or battering an officer.
Previewing 2 of 4 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“the conduct complained of occurred when a police officer attired in casual clothes (tee shirt and bluejeans), without badge, weapons or any other indicia of his status, apparently attempted to arrest appellants' father during an altercation between neighbors.”
Establishes the critical fact that the officer was completely unidentifiable as law enforcement, which is central to the court's analysis of whether the girls could have reasonably known they were obstructing police.
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Join FLexlaw to unlock all legal intelligenceTwo honor students witnessed what appeared to be a violent attack on their father by a stranger in civilian clothes (tee shirt and bluejeans) without …
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OTT, Judge.
Appellants, teenage sisters, were found guilty in juvenile proceedings of obstructing police officers making an arrest, and of committing a battery upon such officers. We believe that under the peculiar facts of this case the evidence presented to the court was not sufficient to sustain the findings of guilt. Accordingly, we reverse.
The trial judge made no findings of the facts upon which he based his judgment, and we have examined the record in vain for evidence to support the judgment of guilt. A full recitation of the factual background of this unusual case would unduly prolong this opinion. Briefly, the conduct complained of occurred when a police officer attired in casual clothes (tee shirt and bluejeans), without badge, weapons or any other indicia of his status, apparently attempted to arrest appellants’ father during an altercation between neighbors. Appellants are honor students with excellent reputations in their community and they have no record of any previous transgressions. They came out of their house just in time to witness what appeared to be a violent attack on their father by a stranger who seemed to be one of the neighbor’s guests. The officer was totally without means of identifying himself as a law enforcement officer. In fact, there was a sharp conflict in testimony as to whether he even attempted to do so. A uniformed officer who had been called to the scene was standing by, and it is not clear whether he ever, while the girls were present, offered to vouch for or otherwise establish the attacker as a police officer acting in any official capacity. When he seemingly ignored the appellants’ frantic appeals to intervene and stop the beating, they personally went to their father’s aid.
We think that the evidence produced by the state, even when given its full weight and effect, was insufficient as a matter of law to establish the guilt of these appellants beyond and to the exclusion of every reasonable doubt.
The orders of the court below adjudicating appellants guilty of the offenses charged against them are reversed.
SCHEB, Acting C. J., and RYDER, J., concur.
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R.M. v. State, 446 So. 2d 1140 (Fla. 3d DCA 1984)…PER CURIAM. Because the evidence was wholly insufficient to support the conclusion that the appellant was guilty of obstructing an officer, L.J.E. v. State, 384 So. 2d 981 (Fla. 2d DCA 1980); English v. State, 293 So. 2d 105 (Fla. 1st DCA 1974), the adjudication of delinquency under review, which was entirely based on that finding, is reversed.…