Tyler v. State
2014 WL 210448, 131 So. 3d 811, 2014 Fla. App. LEXIS 494 (2014)
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Rule of Law:
The prosecution does not bear the constitutional or common law burden of disproving a defendant's affirmative defense of duress beyond a reasonable doubt; instead, the burden of proving duress rests with the defendant.
Facts:
- Antwan J. Tyler was accused of armed robbery with a firearm.
- During his trial, Tyler raised the affirmative defense of duress.
Procedural Posture:
- Antwan J. Tyler was convicted of armed robbery with a firearm by a trial court.
- Tyler appealed his judgment of conviction to the Florida First District Court of Appeal, challenging, among other issues, that the trial court's standard jury instruction on duress was fundamental error for failing to state that the state bore the burden of disproving duress.
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Issue:
Does the standard jury instruction on duress constitute fundamental error by failing to explicitly state that the prosecution bears the burden of proving beyond a reasonable doubt that a defendant did not act out of duress, similar to the burden applied in self-defense cases?
Opinions:
Majority - VAN NORTWICK, J.
No, the standard jury instruction on duress does not constitute fundamental error by failing to explicitly state that the prosecution bears the burden of proving beyond a reasonable doubt that a defendant did not act out of duress. The court clarified that the appellant's argument misreads the precedent of Mosansky v. State, which did not support a burden-shifting instruction for self-defense. Furthermore, the court referenced Dixon v. U.S., establishing that there is no constitutional or modern common law basis for requiring the government to disprove a defendant’s duress defense beyond a reasonable doubt. Historically, the burden of proving affirmative defenses, including justification, excuse, or alleviation, rested upon the defendant, especially since the facts regarding such issues often lie peculiarly within the knowledge of the defendant.
Analysis:
This case clarifies the allocation of the burden of proof for the affirmative defense of duress in Florida, aligning it with federal common law principles. It rejects the attempt to equate the duress defense with self-defense in terms of burden-shifting instructions, preventing an unwarranted expansion of prosecutorial burden. The decision reinforces the general principle that defendants bear the burden of proving affirmative defenses, particularly when the underlying facts are uniquely within their knowledge, thus impacting how juries are instructed and how such defenses are litigated in future cases.
