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Sigler v. State

Citations: 590 So. 2d 18; 1991 WL 248421Docket: 91-0077

Court: District Court of Appeal of Florida; November 26, 1991; Florida; State Appellate Court

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Jay Junior Sigler appealed his convictions for two counts of strong arm robbery and two counts of false imprisonment. The District Court of Appeal of Florida, Fourth District, reversed the false imprisonment convictions due to erroneous jury instructions provided by the trial court. 

The facts revealed that Sigler was a passenger in a car with two men who offered to drive two women to retrieve their towed vehicle. When the women realized they were being taken the wrong way, they requested to exit the vehicle. The driver stopped on a dead-end street, locked the doors, and the men demanded money. After the women claimed they had none, Sigler forcibly pulled one woman from the car, and a struggle ensued. As a result, items were taken from the ground when one woman's purse broke.

The initial jury instruction on false imprisonment included a crucial element allowing for a defense if the confinement was for the purpose of committing or facilitating a felony. However, during deliberations, the trial court altered the instruction, effectively eliminating this defense by failing to include the essential language regarding the intent to commit a felony. This change was deemed fundamentally erroneous as it negated Sigler's only defense.

Consequently, the appellate court reversed the false imprisonment convictions and remanded for a new trial, allowing the trial court discretion to reconsider Sigler's sentencing on remand, although no error was found in the original sentencing. Judges Downey and Anstead concurred with the decision.