ANGEL RIVERA
v.
THE STATE OF FLORIDA

Fla. 3d DCA | 2024-06-12
No. 2022-1307
Logue, C.J., Lobree, J., Bokor, J., Vizcaino, J.
2024 FL 6939 Florida District Court of Appeal, Third District (2024)

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Holding

The trial court's judgment is affirmed under harmless error analysis, which requires the State to prove beyond a reasonable doubt that any error did not contribute to the verdict.


Headnotes

[1] In harmless error analysis, the State must prove beyond a reasonable doubt that any trial error did not contribute to the verdict, and overwhelming evidence of a defendan…

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Key Quotes

“The harmless error test requires the State to 'prove beyond a reasonable doubt that the error complained of did not contribute to the verdict or, alternatively stated, that there is no reasonable possibility that the error contributed to the conviction.'”

Citation to Mantecon v. State, 373 So. 3d 929, 939 (Fla. 1st DCA 2023)

Facts & Procedural History

Angel Rivera appealed a conviction from the Circuit Court for Miami-Dade County. The appeal involved review of potential trial error under harmless er…

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Opinion of the Court
Logue

Third District Court of Appeal State of Florida

Opinion filed June 12, 2024. Not final until disposition of timely filed motion for rehearing.

________________

No. 3D22-1307 Lower Tribunal No. F20-12456 ________________

Angel Rivera, Appellant,

vs.

The State of Florida, Appellee.

An Appeal from the Circuit Court for Miami-Dade County, Diana Vizcaino, Judge.

Carlos J. Martinez, Public Defender, and John Eddy Morrison, Assistant Public Defender, for appellant.

Ashley Moody, Attorney General, and Kayla Heather McNab, Assistant Attorney General, for appellee.

Before LOGUE, C.J., and LOBREE and BOKOR, JJ.

PER CURIAM.

2

Affirmed. See Mantecon v. State, 373 So. 3d 929, 939 (Fla. 1st DCA 2023) (“The harmless error test requires the State to ‘prove beyond a reasonable doubt that the error complained of did not contribute to the verdict or, alternatively stated, that there is no reasonable possibility that the error contributed to the conviction.’”) (quoting in part State v. DiGuilio, 491 So. 2d 1129, 1135 (Fla. 1986)); see also Thorne v. State, 271 So. 3d 177, 185 (Fla. 1st DCA 2019) (“Although DiGuilio states that the harmless error test is not simply one of overwhelming evidence, later supreme court cases suggest that the overwhelming evidence of a defendant's guilt may be considered in the harmless-error analysis where guilt has been established by evidence not related to the claimed error.”).


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