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McFadden v. State
Citations: 732 So. 2d 412; 1999 WL 213019Docket: 98-91
Court: District Court of Appeal of Florida; April 14, 1999; Florida; State Appellate Court
The District Court of Appeal of Florida reversed Gregory McFadden's conviction for domestic battery against Sharon Hudgins, ordering a new trial due to improper evidence introduction. The court found that evidence of McFadden's prior guilty plea to aggravated battery against Hudgins, for which adjudication was withheld, should not have been referenced during trial. According to section 90.610(1) of the Florida Statutes, a withheld adjudication does not constitute a "conviction" suitable for impeachment purposes. The court distinguished this case from previous Florida authority that suggested otherwise, emphasizing a reliance on the interpretation of "conviction" established by the Florida Supreme Court. The decision underscored the legislative intention behind the statute and clarified that the definition of "conviction" must be adhered to as previously interpreted. The court also rejected the prosecution's reliance on a separate case concerning the withdrawal of guilty pleas, affirming its position on the interpretation of evidence admissibility. The lower court erred by allowing the prosecutor to disclose the specifics of McFadden's prior conviction, including the name of the victim, which constituted independent error. Reference is made to relevant case law, such as Sheffield v. State and Porter v. State, underscoring the inappropriateness of detailing damaging specifics. Additionally, McFadden was denied the opportunity to clarify to the jury that he had denied a prior conviction because adjudication was withheld, as referenced in Lawhorne v. State and Williams v. State. This ruling was deemed incorrect regardless of whether McFadden's guilty plea was admissible for impeachment. The court determined that these errors were not harmless, as they significantly impacted the jury's decision in a case primarily based on conflicting testimonies between McFadden and the victim's teenage son. Consequently, the judgment was reversed, and a new trial was ordered.