Seymour v. State

Citations: 132 So. 3d 300; 2014 Fla. App. LEXIS 392; 2014 WL 169787Docket: No. 4D13-4649

Court: District Court of Appeal of Florida; January 13, 2014; Florida; State Appellate Court

SummaryOriginalCytator Case TreatmentBackward CitatorAnalysis

EnglishEspañolSimplified EnglishEspañol Fácil

Dallas Seymour filed an emergency petition for a writ of habeas corpus, seeking to overturn the trial court's denial of bond following an Arthur hearing and requesting a reasonable bond. The charges against him include second degree murder and possession of a firearm by a convicted felon. The murder charge alleges that Seymour unlawfully killed Darryl Keith Hardnett through an act demonstrating a depraved mind without intent to kill, specifically by shooting Hardnett. This charge is punishable by life imprisonment.

Seymour contended that the evidence suggested an accidental shooting, arguing that the state did not meet the burden of proving "proof evident or presumption great" necessary for bond denial under Florida law. The trial court reviewed evidence including witness statements and video surveillance. The evidence revealed that Seymour, while socializing with others, handled a firearm which accidentally discharged, resulting in Hardnett's death. Eyewitness accounts indicated no prior argument and described the shooting as a pure accident.

Despite Seymour’s claims and the defense's argument that the evidence could support lesser charges (like manslaughter or culpable negligence), the trial court denied his motion for bond, asserting that the state had presented sufficient evidence to potentially sustain a guilty verdict. The court acknowledged that the state must meet a higher standard of proof than beyond a reasonable doubt for bond denial.

The court determined that the state had met its burden of proof sufficient to justify a guilty verdict, leading to the denial of bond for the Petitioner. After the trial court rejected the Petitioner’s motion to reconsider this denial, the Petitioner filed a habeas corpus petition, which is an appropriate remedy for challenging such incarceration. According to Article I, section 14, of the Florida Constitution, individuals charged with non-capital offenses are entitled to pretrial release unless the state can demonstrate that the evidence of guilt is evident or the presumption of guilt is great. This standard is stricter than the burden of proof for a criminal conviction. The court noted that in previous cases, such as Elderbroom and Kirkland, the state failed to meet this stringent burden when substantial evidence contradicted the state’s case. In Elderbroom, the trial court erred in denying bond despite evidence supporting both sides, as the defendant presented an alibi and challenged crucial aspects of the state’s case. Similarly, in Kirkland, the state's evidence was inadequate to establish the defendant's guilt, as it relied on inconsistent unsworn statements. Consequently, the court concluded that the trial court did not adequately find that the state met its burden in denying bond to the Petitioner.

A wife alleged that the defendant claimed he and the alleged perpetrator were involved in business dealings with the victim, and that the alleged perpetrator had the defendant's knife. The seventeen-year-old defendant denied these allegations, stating he was in the alleged perpetrator's truck on the murder day and believed his knife had fallen out. The trial court found the state did not meet its burden to prove the defendant's guilt was evident. Citing precedents, the court noted that while evidence could support a guilty verdict for second-degree murder, the standard requires proof beyond doubt, not just a prima facie case. The court dismissed the state's claim that the defendant's attempt to discard the gun indicated guilt, emphasizing that he might have acted out of fear as a convicted felon. Therefore, the trial court was found to have abused its discretion, leading to the granting of the petition for bail. Additionally, the definition of second-degree murder was reiterated, highlighting the standards required to demonstrate a depraved mind and dangerous conduct.