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State Courts -
Florida - March 4, 2009
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DeBolt v. State (In re Commitment of DeBolt), Case No. 2D07-2174,
COURT OF APPEAL OF FLORIDA, SECOND DISTRICT, March 4, 2009, Decided, March 4, 2009, Opinion Filed
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Overview: Trial court abused its discretion in allowing the State to question appellant's expert in a Jimmy Ryce Act proceeding about a prior disciplinary matter; the question went far beyond the type of impeachment questions allowed by ¿¿ 90.609, 90.610, Fla. Stat., and as experts were focal point of the trial, the error could not be deemed harmless.
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J.M. v. Dep't of Children & Families, No. 4D08-3313,
COURT OF APPEAL OF FLORIDA, FOURTH DISTRICT, March 4, 2009, Decided
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Overview: While a court should not have entered a consent to the termination of parental rights petition under ¿ 39.801(3)(d), Fla. Stat., the error did not require a reversal since, despite the entry of the consent, the mother fully participated in the proceedings and there was competent substantial evidence to support the court's findings.
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