DANYAN MANGHAM
v.
STATE

Fla. 3d DCA | 2021-04-07
No. 20-0382
Tinkler Mendez, J., Fernandez, J., Lindsey, J., Bokor, J.
Florida District Court of Appeal, Third District (2021) Positive Treatment

AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.


Holding

Expert testimony may not be used as a conduit for introducing otherwise inadmissible evidence, and trial courts have discretion to weigh probative value against prejudicial impact in evidentiary rulings.


Headnotes

[1] Expert testimony may not be used as a conduit for the introduction of otherwise inadmissible evidence.

[2] A trial court's decision to weigh probative value against prejudicial impact in admitting evidence will not be overturned on appeal absent a clear abuse of discretion.

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Key Quotes

“an expert's testimony 'may not merely be used as a conduit for the introduction of the otherwise inadmissible evidence'”

Citing Dayes v. Werner Enterprises, Inc. and Linn v. Fossum regarding limitations on expert testimony

Facts & Procedural History

Danyan Mangham appealed a decision from the Circuit Court for Miami-Dade County regarding the admissibility of expert testimony and business records.…

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Opinion of the Court

PER CURIAM.

Affirmed. Dayes v. Werner Enterprises, Inc., No. 3D19-1920, 2021 WL 262037, at *4 (Fla. 3d DCA Jan. 27, 2021) (quoting Linn v. Fossum, 946 So. 2d 1032, 1037-38 (Fla. 2006)) (“an expert’s testimony ‘may not merely be used as a conduit for the introduction of the otherwise inadmissible evidence’”); 50 State Sec. Serv., Inc. v. Giangrandi, 132 So. 3d 1128, 1136 (Fla. 3d DCA 2013) (“Where a trial court has weighed probative value against prejudicial impact before reaching its decision, an appellate court shall not overturn such a decision absent a clear abuse of discretion.”) (internal citations omitted); Osagie v. State, 58 So. 3d 307, 308 (Fla. 3d DCA 2011) (finding error in admitting business records “without a custodian of the records or other qualified person testifying as to the accuracy of the records”).

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