Karls v State – Error to Exclude Evidence of Non-Impairment in DUI

Florida law is clear that “where evidence tends in any way, even indirectly, to establish a reasonable doubt of defendant’s guilt, it is error to deny its admission.” (Rivera v. State, 561 So. 2d 536, 539 (Fla. 1990)

Karls was convicted by a jury and sentenced to 270 days in jail, followed by 12 months of probation and a 10-year suspension of his driver’s license. The conviction stemmed from a December 9, 2022, motorcycle crash in Safety Harbor, Florida, where Karls collided with a car while allegedly impaired. Evidence against him included eyewitness accounts, bodycam footage showing incoherent behavior, a failed field sobriety test, and a positive urine test.

At trial, defense counsel sought to call Karls’ mother, Beverly Karls, to testify that she was with her son at home until approximately 30 minutes before the accident—and during that time, she saw no signs of alcohol or drug consumption. The State objected on relevance grounds, and the trial court sustained the objection, excluding her testimony. You may believe it is shocking that a State Attorney would make this kind of objection since it is so incredibly obvious that the testimony is relevant. Or you may be shocked that a Judge agreed with the State and sustained the objection. But if you are shocked that just means you aren’t aware of how many types of errors can occur during a criminal trial and why criminal defense lawyers fight so hard to preserve the law and enforce peoples rights one case at a time.

The appellate court found reversible error in the trial court’s exclusion of Ms. Karls’ testimony. While trial courts have discretion in evidentiary rulings, that discretion is constrained by legal principles and constitutional guarantees. As noted in Thomas v. State, 363 So. 3d 1153, 1154 (Fla. 2d DCA 2023), evidentiary rulings must comply with applicable law.

Florida law, as reiterated in Mateo v. State, 932 So. 2d 376, 379–80 (Fla. 2d DCA 2006), is clear: “Where evidence tends in any way, even indirectly, to establish a reasonable doubt of defendant’s guilt, it is error to deny its admission.” This principle derives from the U.S. Supreme Court’s recognition in Chambers v. Mississippi, 410 U.S. 284, 302 (1973), that the right to present witnesses in one’s own defense is fundamental.

The court emphasized that the excluded testimony was relevant to the central issue of whether Karls was impaired at the time of the accident—a fact the State had to prove beyond a reasonable doubt. The Florida Constitution and the U.S. Constitution guarantee a criminal defendant the right to present witnesses in their defense. See U.S. Const. amend. V; Fla. Const. art. I, § 9; see also Olson v. Blasco, 676 So. 2d 481, 482 (Fla. 4th DCA 1996).

Further, Florida case law holds that when the relevance of proffered evidence is in doubt, the defendant is entitled to the benefit of that doubt. See Panaro v. State, 398 So. 3d 1115, 1119 (Fla. 2d DCA 2024); Vannier v. State, 714 So. 2d 470, 472 (Fla. 4th DCA 1998).

Under Florida’s harmless error standard, the State bears the burden of showing beyond a reasonable doubt that the error did not contribute to the verdict. See State v. DiGuilio, 491 So. 2d 1129, 1135 (Fla. 1986); Davis v. State, 347 So. 3d 315, 323 (Fla. 2022). Here, the appellate court found that the State failed to meet this burden, noting that Ms. Karls’ testimony could have cast doubt on whether her son was impaired at the time of the crash.

The appellate court reversed the judgment and sentence and remanded the case for a new trial, holding that the exclusion of relevant defense testimony violated Karls’ constitutional right to present a defense.

This case serves as a strong reminder for defense attorneys to preserve the right to present relevant defense evidence and challenge improper exclusions vigorously—especially when such exclusions may infringe on constitutional rights.

Ricky Karls v State 2D2024-0325

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