Stannard v. State
2013 WL 275250, 2013 Fla. App. LEXIS 1034, 113 So.3d 929 (2013)
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Rule of Law:
A trial court must instruct the jury on a defendant's asserted defense if there is any evidence to support it, when viewed in the light most favorable to the defendant; the court may not refuse the instruction by weighing the credibility of the evidence.
Facts:
- Brian Robert Stannard owed $150 to a drug dealer named Pops for oxycodone he had purchased on credit.
- Pops and his friends repeatedly threatened Stannard for the money, causing Stannard and his mother to move to a new residence to avoid them.
- Pops located Stannard at his new home, and on April 18, 2010, he and his associates forcibly placed Stannard in a vehicle.
- Inside the vehicle, one of the men threatened to beat Stannard so badly that his mother would not recognize him if he did not settle his debt.
- Pops drove Stannard to a Walgreens, provided him with a fraudulent prescription already filled out in his name, and ordered him to fill it to clear his debt.
- Several of Pops' associates accompanied Stannard into the store and remained within his line of sight while he was at the pharmacy counter.
- After the pharmacist filled the prescription, the men took the drugs from Stannard before they left the store.
Procedural Posture:
- The State of Florida charged Brian Robert Stannard with trafficking in oxycodone and obtaining a prescription by fraud in a Florida trial court.
- At the conclusion of the trial, Stannard's counsel requested a standard jury instruction on the defense of duress.
- The trial court denied the request for the jury instruction, finding Stannard's testimony not credible and the alleged threat not sufficiently imminent.
- The jury found Stannard guilty as charged.
- Stannard, as appellant, appealed his convictions to the Florida Fifth District Court of Appeal, with the State of Florida as appellee.
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Issue:
Does a trial court commit reversible error by refusing to instruct the jury on the defense of duress when the defendant presents testimony supporting each element of the defense, even if the court personally finds that testimony not credible?
Opinions:
Majority - Griffin, J.
Yes, the trial court commits reversible error. A defendant is entitled to have the jury instructed on their theory of defense if any evidence supports it, and the trial court's role is not to weigh the credibility of that evidence. The court must examine the evidence in the light most favorable to the defendant to determine if the necessary elements of the defense have been placed before the jury. Stannard's testimony provided evidence of a direct threat of imminent, serious bodily harm which caused him to commit the crime. Whether his story was credible, the threat was truly imminent, and whether he had a reasonable means of escape (such as alerting the pharmacist) are questions of fact for the jury to decide, not the judge. The trial court usurped the jury's function by making these credibility and factual determinations itself, which constitutes a reversible error.
Analysis:
This decision reaffirms the fundamental division of responsibility between the judge and the jury in a criminal trial. It establishes that the judge acts as a gatekeeper for legal theories, ensuring there is a minimal evidentiary basis for a defense, but cannot step into the jury's role as the ultimate arbiter of fact and credibility. The ruling protects a defendant's right to present a complete defense by preventing trial judges from prematurely dismissing a defense based on their personal assessment of the evidence. Consequently, as long as a defendant can articulate a version of events that touches upon all elements of a recognized defense, the jury must be instructed on it, preserving the integrity of the jury's fact-finding function.
