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Balthazar v. State

Citations: 533 So. 2d 955; 13 Fla. L. Weekly 2582; 1988 Fla. App. LEXIS 5134; 1988 WL 123790Docket: No. 4-86-1413

Court: District Court of Appeal of Florida; November 22, 1988; Florida; State Appellate Court

Narrative Opinion Summary

Defendant’s conviction is affirmed, with the court employing the preponderance of the evidence standard to evaluate the voluntariness of the defendant’s confession. This standard is consistently applied in Florida cases concerning confession voluntariness, as established in McDole v. State. The court acknowledges the defendant’s limited understanding of English but maintains that the burden of proof for the state remains at preponderance of the evidence rather than shifting to a clear and convincing standard, as supported by precedent in DeCo-ningh v. State and Rodriguez v. State. Judges Glickstein, Walden, and Stone concur in the decision.

Legal Issues Addressed

Language Barrier Consideration in Confession Voluntariness

Application: The court acknowledges the defendant's limited English proficiency but maintains the standard of proof at preponderance of the evidence, as supported by legal precedents.

Reasoning: The court acknowledges the defendant’s limited understanding of English but maintains that the burden of proof for the state remains at preponderance of the evidence rather than shifting to a clear and convincing standard, as supported by precedent in DeCo-ningh v. State and Rodriguez v. State.

Precedent on Confession Voluntariness Standard

Application: The decision aligns with the precedent set in McDole v. State, which confirms the use of the preponderance of the evidence standard in Florida for confession voluntariness.

Reasoning: This standard is consistently applied in Florida cases concerning confession voluntariness, as established in McDole v. State.

Standard for Evaluating Confession Voluntariness

Application: The court applies the preponderance of the evidence standard to determine the voluntariness of the defendant’s confession, consistent with established Florida case law.

Reasoning: Defendant’s conviction is affirmed, with the court employing the preponderance of the evidence standard to evaluate the voluntariness of the defendant’s confession.