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R.C. v. State

Citations: 793 So. 2d 1078; 2001 Fla. App. LEXIS 11074Docket: No. 2D00-3520

Court: District Court of Appeal of Florida; August 8, 2001; Florida; State Appellate Court

Narrative Opinion Summary

In this case, the appellant, R.C., contested the trial court's denial of his motion for judgment of acquittal related to a burglary charge. The primary legal issue centered on whether R.C. possessed the requisite intent to commit an offense at the time of entry into a vacant mobile home. The court found that there was insufficient evidence to demonstrate such intent, resulting in the reversal of the burglary conviction. The evidence presented indicated that R.C. entered the mobile home without permission and wrote on a wall, yet lacked the intent to commit criminal mischief upon entry. R.C. admitted to being present during the break-in by a friend but claimed his subsequent entry was not accompanied by criminal intent. The court upheld a conviction for trespass, recognizing it as a lesser included offense, based on R.C.'s acknowledged unauthorized entry. Additionally, the court noted that recent statutory changes concerning intent did not apply retroactively to this case. The outcome mandated a new disposition hearing for the trespass charge, effectively altering the original burglary finding to trespass.

Legal Issues Addressed

Burglary and Intent

Application: The court determined that the evidence was insufficient to establish that R.C. had the intent to commit an offense at the time of entry, leading to the reversal of the burglary charge.

Reasoning: The court found insufficient evidence to support that R.C. had the intent to commit an offense at the time he entered the mobile home, leading to a reversal of the burglary finding.

Impact of Law Changes on Intent

Application: The court clarified that changes in the law regarding intent do not affect this case as the events occurred before the relevant statute's retroactive application.

Reasoning: The court also clarified that changes in the law regarding intent do not affect this case since the events occurred before the relevant statute's retroactive application.

Trespass as a Lesser Included Offense

Application: The court upheld a trespass charge based on R.C.'s admission of entering the premises without permission, despite the absence of intent to commit a crime.

Reasoning: Consequently, the court upheld a finding of trespass, a lesser included offense, based on R.C.'s admission of entering without permission.