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Guthrie v. State
Citations: 637 So. 2d 35; 1994 WL 180456Docket: 92-04232
Court: District Court of Appeal of Florida; May 11, 1994; Florida; State Appellate Court
Ronald E. Guthrie appealed his conviction for first-degree murder after a jury found him guilty of killing Elizabeth Martin. The indictment arose from allegations that Guthrie and Alex Martin, Elizabeth's son with whom Guthrie had a homosexual relationship, plotted her murder to collect insurance benefits and property proceeds. During his custody, Guthrie confessed to killing Elizabeth for these financial gains. The jury recommended life imprisonment, which was adjudicated by the court. Guthrie's appeal focused solely on the admissibility of evidence regarding his homosexuality, arguing it improperly attacked his character as he had not placed his character at issue. The prosecution maintained that this evidence was essential to establish motive for the murder. The court affirmed the trial court's decision, citing Florida case law that allows relevant evidence to prove a fact in issue, including motive, unless it solely aims to demonstrate bad character. Since Guthrie was not charged with any homosexual acts and the evidence was pertinent to motive, the appellate court upheld the trial court’s ruling to admit the evidence, thereby rejecting Guthrie's arguments. The appellant and Alex Martin discussed killing Ms. Martin to secure insurance proceeds and profits from selling a property, with Alex promising to care for the appellant afterward. Testimony about the appellant and Alex's homosexual relationship was deemed relevant to establish motive and was therefore admissible, supported by case law (State v. Statewright, Toole v. State, Michael v. State, Alford v. State). The trial court ruled that the evidence's probative value outweighed any potential prejudicial impact. Even if the evidence had been improperly admitted, the court would not have reversed the decision due to the appellant's failure to object during the trial, despite filing a motion in limine. This lack of objection constituted a waiver of the issue. The court affirmed the appellant's judgment and sentence.