IN THE INTEREST OF M.J.H., A CHILD
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The court held that presence at the scene of a crime and flight therefrom are insufficient to prove the requisite knowledge and intent for guilt.
M.J.H. was present at the scene of a car break-in and fled upon discovery. The state's evidence showed he was on the passenger side of the car, which …
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[*85] WIGGINTON, Judge.
M.J.H. appeals from his adjudication of delinquency and commitment to the Department of Health and Rehabilitative Services. We reverse.
As the state relied entirely upon circumstantial evidence, it was incumbent upon it to present evidence inconsistent with any and all reasonable hypotheses of innocence. G.H. v. State, 599 So. 2d 231 (Fla. 3d DCA 1992). Instead, the state’s only evidence against M.J.H. was that he was present at the scene of the commission of the crime and that he fled therefrom upon discovery. At most, the state’s witness could only testify that he observed M.J.H. standing on the passenger side of an automobile being broken into from the driver’s side. M.J.H. was never observed leaning inside or in any way entering or attempting to enter the automobile. Although the door on the passenger side was slightly cracked and the lock had been jimmied, there was no evidence that MJ.H.’s prints were on the lock, on the door, or anywhere on the car; or that M.J.H. was found in possession of any kind of tool or equipment to jimmy the lock.
Since it is axiomatic that presence at the scene of a crime and flight upon discovery are insufficient to prove the requisite knowledge and intent necessary to support a finding of guilt, the motion for judgment of acquittal should have been granted. Cf. J.W. v. State, 467 So. 2d 796 (Fla. 3d DCA 1985). Consequently, the order of adjudication and commitment is reversed and the case remanded with directions to discharge appellant.
REVERSED and REMANDED.
ALLEN and WEBSTER, JJ., concur.
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J.R.S. v. State, 702 So. 2d 540 (Fla. 2d DCA 1997)…in the hamper on his way out of the garage that morning, and simply forgot to close the garage door. We believe that this case is similar to the cases cited by appellant, M.F. v. State, 549 So. 2d 225 (Fla. 3d DCA 1989), In the Interest of M.J.H., 610 So. 2d 84 (Fla. 1st DCA 1992), and F.B. v. State, 605 So. 2d 578 (Fla. 3d DCA 1992), where the appellate court reversed because the only evidence against the defendant was the suspect’s presence at the scene-and his subsequent.flight. This case, however, pres…
Authorities Cited
- J.W. v. State, 467 So. 2d 796 (Fla. 3d DCA 1985)
- G.H. v. State, 599 So. 2d 231 (Fla. 3d DCA 1992)