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Two men fighting in a parking lot, and pointing fingers. Who was defending themselves? That question is frequently brought to Court by people claiming self-defense, and a Judge will have to sort through it before it can reach a jury. However, Problems arise when Court’s refuse to make credibility determinations or attempt to resolve conflicting accounts of a fight. Sometimes it’s easier to just look at the end result (here a broken nose) and just assume the injury makes any use of force unlawful – but that is not the law in Florida, as pointed out by the Appellate Court in the recent Martin case.
n Martin v. State, the Florida Fourth District Court of Appeal (covering Broward County) granted a writ of prohibition in favor of Miguel Antonio Martin, overturning a trial court’s denial of his motion to dismiss based on Florida’s Stand Your Ground law. The appellate court held that the State failed to overcome Martin’s immunity claim with clear and convincing evidence, and found that Martin’s use of force was legally justified under the circumstances.
Florida Court Grants “Stand Your Ground” Immunity in Valet Altercation
Background
Martin, a one-armed valet, was charged with battery on a person over 65 following a workplace dispute. He sought immunity under section 776.032(1), Florida Statutes (2023), arguing he acted in lawful self-defense. During the evidentiary hearing, video and eyewitness accounts indicated Martin attempted to disengage multiple times before striking the alleged victim, who had approached him aggressively, threatened him, and grabbed his shirt.
Legal Framework
Florida’s Stand Your Ground law grants criminal immunity to individuals who use non-deadly force if they “reasonably believe that such conduct is necessary to defend himself or herself… against the other’s imminent use of unlawful force.”
§ 776.012(1), Fla. Stat. (2023).
Once a prima facie claim of self-defense is made, the burden shifts to the State to refute immunity by “clear and convincing evidence”—a standard requiring that the evidence be “of sufficient weight to convince the trier of fact without hesitancy.” (Guida v. State, 356 So. 3d 310, 311 (Fla. 5th DCA 2023)(quoting Edwards v. State, 257 So. 3d 586, 588 (Fla. 1st DCA 2018).
The trial court had ruled that Martin’s punch, which broke the alleged victim’s nose, was not “proportional to the event” and thus not justified. However, the appellate court disagreed, and went on to explain why the lower Court ruled incorrectly, primarily due to not addressing the credibility of Mr. Martin’s belief in danger, and instead focusing on the broken nose.
Court’s Reasoning
The court applied an objective standard, asking whether: “A reasonable and prudent person situated in the same circumstances and knowing what the defendant knew would have used the same force.” (Huckelby v. State, 313 So. 3d 861, 866 (Fla. 2d DCA 2021), quoting Garcia v. State, 286 So. 3d 348, 351 (Fla. 2d DCA 2019)).
The panel highlighted several key facts:
Martin’s physical limitation (having only one arm),
The alleged victim’s verbal threats during a heated exchange,
The alleged victim “getting close” and raising his voice (admitted by the victim),
Martin’s testimony that he believed the victim wanted to harm him,
The victim putting his finger in Martin’s face and grabbing his shirts Martin attempted to walk away.
These factors, the court held, would lead a reasonable and prudent person to conclude that the use of force was necessary and proportional based on the circumstances as they appeared to the Defendant. Therefore, the State failed to meet its burden and Mr. Martin should be immune from prosecution.
Conclusion: This case reinforces the protective scope of Florida’s Stand Your Ground statute and clarifies that courts must assess self-defense claims using an objective, reasonable-person standard. It also underscores that appellate courts may override trial courts’ legal conclusions when unsupported by a proper application of that standard.
Everyone wants a fair and impartial judiciary, where they get due process and someone who will follow the law and hear them out. Florida protects the rights of its citizens with a huge range of procedural safeguards and statutes designed to bring common sense to our Courts and lives. But the way these laws are used matters, and unless the laws are executed fairly and evenly, and every citizen knows how to use them, everyone is at risk of being taken advantage of by neglectful government prosecutions, lying witnesses and faking alleged victims, and snap judgements that can get you wrongfully incarcerated.
Hopefully here, not too much harm was done to Mr. Martin’s life before his immunity was granted, but until it was, he had to endure physical and emotional stress and have his life slandered and disrupted simply for defending himself.
Citation: Martin v. State, 4D2025-0304 (Fla. 4th DCA 2025)
Ricky Karls v State 2D2024-0325
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