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State v. Mendiola

Citations: 613 So. 2d 612; 1993 Fla. App. LEXIS 2221; 1993 WL 46135Docket: No. 91-2520

Court: District Court of Appeal of Florida; February 23, 1993; Florida; State Appellate Court

Narrative Opinion Summary

The state appeals the trial court's dismissal of trafficking in cocaine and conspiracy charges against Alejandro Mendiola and Giovanna Castillo. Castillo was introduced to a drug deal by a confidential informant, who later facilitated Mendiola's involvement. The court reverses the dismissal for Mendiola based on precedent from Hunter v. State, which supports the notion that mere participation in a drug deal does not constitute an automatic dismissal. Conversely, the court affirms the dismissal of charges against Castillo, concluding that the trial court's findings indicate entrapment as a matter of law, referencing State v. Evans. Judges Anstead, Warner, and Senior Judge Owen concur with the decision.

Legal Issues Addressed

Affirmation of Entrapment as a Defense

Application: The appellate court affirmed the trial court's dismissal of charges against Castillo, concluding that the evidence supported a finding of entrapment as a matter of law.

Reasoning: Conversely, the court affirms the dismissal of charges against Castillo, concluding that the trial court's findings indicate entrapment as a matter of law, referencing State v. Evans.

Reversal of Dismissal for Drug Trafficking Charges

Application: The appellate court reversed the trial court's dismissal of trafficking in cocaine and conspiracy charges against Mendiola, based on legal precedent that mere participation does not warrant automatic dismissal.

Reasoning: The court reverses the dismissal for Mendiola based on precedent from Hunter v. State, which supports the notion that mere participation in a drug deal does not constitute an automatic dismissal.

Role of Confidential Informants in Drug Prosecutions

Application: The involvement of a confidential informant in introducing Castillo to the drug deal played a significant role in the determination of entrapment by the trial court.

Reasoning: Castillo was introduced to a drug deal by a confidential informant, who later facilitated Mendiola's involvement.