OLIVER S. STEEL
v.
STATE OF FLORIDA

Fla. 4th DCA | 2018-03-14
No. 18-0498
244 So. 3d 1095 Florida District Court of Appeal, Fourth District (2018)

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Holding

The circuit court properly denied the defendant's Rule 3.800(a) motion challenging the constitutionality of his first-degree murder sentence.


Headnotes

[1] A trial court commits reversible error by excluding impeachment testimony when an adequate predicate has been laid for the witness's prior inconsistent statement.

[2] When the credibility of an eyewitness is crucial to a case, the exclusion of evidence that could impeach that witness's testimony cannot be considered harmless error.

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Facts & Procedural History

Oliver Steel was convicted of first-degree murder in 1989. In January 2018, he filed a motion challenging his sentence as unconstitutional.…

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Opinion of the Court

Consolidated appeals from order denying rule 3.800(a) motion from the Circuit Court for the Seventeenth Judicial Circuit, Broward County; Edward H. Merrigan, Jr., Judge; L.T. Case No. 89-26582CF10B.

Oliver S. Steel, Okeechobee, pro se. No appearance required for appellee. PER CURIAM. Oliver Steel challenges the January 2, 2018 order of the Seventeenth Judicial Circuit that denied his challenge to his sentence for first degree murder as unconstitutional. He has challenged the order on its merits in 4D18-498, and by petition for writ of certiorari challenged the circuit court’s jurisdiction to enter the order in 4D18-467. We redesignate the certiorari petition to be a final appeal of the January 2, 2018 order, consolidate the two cases and affirm the circuit court’s order. See Alvarez v. State, 358 So. 2d 10 (Fla. 1978); Baron v. State, 39 So. 3d 1274 (Fla. 4th DCA 2010); Ratliff v. State, 914 So. 2d 938 (Fla. 2005). Affirmed. WARNER, LEVINE and CONNER, JJ., concur.

* * * Not final until disposition of timely filed motion for rehearing.


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