Florida Statute 90.608 - Full Text and Legal Analysis

The 2025 Florida Statutes

Title VII
EVIDENCE

Chapter 90
EVIDENCE CODE

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F.S. 90.608

90.608 Who may impeach.—Any party, including the party calling the witness, may attack the credibility of a witness by:

(1) Introducing statements of the witness which are inconsistent with the witness’s present testimony.

(2) Showing that the witness is biased.

(3) Attacking the character of the witness in accordance with the provisions of s. 90.609 or s. 90.610.

(4) Showing a defect of capacity, ability, or opportunity in the witness to observe, remember, or recount the matters about which the witness testified.

(5) Proof by other witnesses that material facts are not as testified to by the witness being impeached.

History.—s. 1, ch. 76-237; s. 1, ch. 77-77; ss. 14, 22, ch. 78-361; ss. 1, 2, ch. 78-379; s. 1, ch. 90-174; s. 488, ch. 95-147.

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F.S. 90.608 on CourtListener

Amendments to 90.608

Annotations, Discussions, Cases:

Cases Citing Statute 90.608

Total Results: 322

Robertson v. State

829 So. 2d 901, 2002 WL 31267817

Supreme Court of Florida | Filed: Oct 10, 2002 | Docket: 350394

Cited 231 times | Published

404(1)(c) that is pertinent in this case is section 90.608(5), Florida Statutes (1997), which provides:

Rodriguez v. State

753 So. 2d 29, 2000 WL 124379

Supreme Court of Florida | Filed: Feb 3, 2000 | Docket: 2514803

Cited 157 times | Published

as substantive evidence against Rodriguez. See § 90.608, Fla. Stat. (1997). The question here is whether

Morrison v. State

818 So. 2d 432, 2002 WL 432561

Supreme Court of Florida | Filed: Mar 21, 2002 | Docket: 1169841

Cited 103 times | Published

So.2d 288, 291 (Fla.1995). In relevant part, section 90.608(2), Florida Statutes (1997), states: Any party

Gudinas v. State

693 So. 2d 953, 1997 WL 166238

Supreme Court of Florida | Filed: Apr 10, 1997 | Docket: 1144752

Cited 84 times | Published

only. State v. Smith, 573 So.2d 306 (Fla.1990); § 90.608, Fla.Stat. (1993). We also agree with the State

David Ross Delap, Sr. v. Richard L. Dugger, Secretary, Department of Corrections, State of Florida

890 F.2d 285, 1989 WL 140400

Court of Appeals for the Eleventh Circuit | Filed: Nov 20, 1989 | Docket: 822762

Cited 83 times | Published

the evidence would be admissible under Fla.Stat. § 90.608 as evidence of bias in this case, where no criminal

Ellis v. State

622 So. 2d 991, 1993 WL 241044

Supreme Court of Florida | Filed: Jul 1, 1993 | Docket: 1529031

Cited 74 times | Published

admitted for purposes of impeachment under section 90.608, Florida Statutes (1989).[3] We cannot accept

Morton v. State

689 So. 2d 259, 1997 WL 93765

Supreme Court of Florida | Filed: Mar 6, 1997 | Docket: 1477519

Cited 66 times | Published

185, 15 So. 905 (1894). By the adoption of section 90.608, Florida Statutes (Supp. 1976), as part of

Johnson v. State

969 So. 2d 938, 2007 WL 1933048

Supreme Court of Florida | Filed: Jul 5, 2007 | Docket: 1403693

Cited 55 times | Published

different view of the facts by other witnesses. § 90.608(5), Fla. Stat. (2006). Responding to the prosecutor's

Jackson v. State

451 So. 2d 458

Supreme Court of Florida | Filed: May 10, 1984 | Docket: 1741210

Cited 50 times | Published

the state to cross-examine and impeach Sutton, § 90.608(2), Florida Statutes (1979), whereupon Sutton

Pearce v. State

880 So. 2d 561, 2004 WL 1469337

Supreme Court of Florida | Filed: Jul 1, 2004 | Docket: 1689202

Cited 48 times | Published

ways to attack the credibility of a witness. See § 90.608(1), Fla. Stat. (2001); see also Charles W. Ehrhardt

State v. Lewis

838 So. 2d 1102, 2002 WL 31769281

Supreme Court of Florida | Filed: Dec 12, 2002 | Docket: 461357

Cited 45 times | Published

648 So.2d 660, 664 (Fla.1994). Pursuant to section 90.608, Florida Statutes (1997), any party may attack

Wasko v. State

505 So. 2d 1314, 12 Fla. L. Weekly 123

Supreme Court of Florida | Filed: Mar 5, 1987 | Docket: 293020

Cited 44 times | Published

doubt by attempting to impeach his testimony. § 90.608(2), Fla. Stat. (1985). Wasko has demonstrated

Rose v. State

787 So. 2d 786, 2001 WL 326690

Supreme Court of Florida | Filed: Apr 5, 2001 | Docket: 1745064

Cited 43 times | Published

195-96 (Fla.1997). As a form of impeachment, section 90.608(1), Florida Statutes (1997), provides, for

Jaggers v. State

536 So. 2d 321, 1988 WL 137176

District Court of Appeal of Florida | Filed: Dec 20, 1988 | Docket: 1759626

Cited 41 times | Published

section to be used to avoid the provision of section 90.608(1) that prohibits a party from impeaching his

Butler v. State

842 So. 2d 817, 2003 WL 1786712

Supreme Court of Florida | Filed: Apr 3, 2003 | Docket: 1440370

Cited 40 times | Published

the relationship between Butler and Fleming. Section 90.608, Florida Statutes (1997), provides: 90.608

Ryan v. State

457 So. 2d 1084

District Court of Appeal of Florida | Filed: Sep 19, 1984 | Docket: 1522374

Cited 40 times | Published

impeaching one's own witness in contravention of Section 90.608(1)(a), Florida Statutes (1983). The State attempts

Dessaure v. State

891 So. 2d 455, 2004 WL 2797213

Supreme Court of Florida | Filed: Dec 2, 2004 | Docket: 1349807

Cited 37 times | Published

they committed perjury. A. APPLICABLE LAW Section 90.608(2), Florida Statutes (2001), states that a

Dennis v. State

817 So. 2d 741, 2002 WL 122250

Supreme Court of Florida | Filed: Jan 31, 2002 | Docket: 1429536

Cited 37 times | Published

was provided by Stafford opened the vehicle. Section 90.608, Florida Statutes (1997), provides that "[a]ny

Brookings v. State

495 So. 2d 135, 11 Fla. L. Weekly 445

Supreme Court of Florida | Filed: Aug 28, 1986 | Docket: 1727651

Cited 33 times | Published

and, used as such, it was not in violation of section 90.608(1)(a), Florida Statutes (1983). Bell v. State

Shere v. State

579 So. 2d 86, 1991 WL 45123

Supreme Court of Florida | Filed: Apr 4, 1991 | Docket: 2041247

Cited 32 times | Published

cross-examine and impeach their own witnesses. § 90.608, Fla. Stat.[11] "This rule resulted from a belief

Sias v. State

416 So. 2d 1213

District Court of Appeal of Florida | Filed: Jul 20, 1982 | Docket: 1224654

Cited 29 times | Published

opposition by showing that the witness is biased. See § 90.608(1)(b), Fla. Stat. (1979). "It is permissible to

Bell v. State

965 So. 2d 48, 2007 WL 1628143

Supreme Court of Florida | Filed: Jun 7, 2007 | Docket: 57018

Cited 26 times | Published

is therefore a proper subject for impeachment. § 90.608, Fla. Stat. (1995). The State addressed these

Gibson v. State

661 So. 2d 288, 1995 WL 582212

Supreme Court of Florida | Filed: Oct 5, 1995 | Docket: 2525553

Cited 26 times | Published

bias or motive of a witness. In relevant part, section 90.608(2) states: Any party, including the party calling

Hamilton v. State

703 So. 2d 1038, 1997 WL 655899

Supreme Court of Florida | Filed: Oct 23, 1997 | Docket: 1349336

Cited 25 times | Published

inconsistent statement before the jury. See generally § 90.608, Fla. Stat. (1995). We disagree. Hamilton's argument

Cruse v. State

588 So. 2d 983, 1991 WL 216127

Supreme Court of Florida | Filed: Oct 24, 1991 | Docket: 1708205

Cited 24 times | Published

ability to observe, remember, or recount. See § 90.608, Fla. Stat. (1987). Cruse was attempting to introduce

Blanton v. State

880 So. 2d 798, 2004 WL 1799760

District Court of Appeal of Florida | Filed: Aug 13, 2004 | Docket: 442825

Cited 23 times | Published

to use the deposition for any purpose. See e.g. § 90.608, Fla. Stat. (2003).[4] *802 Appellant's second

Ortagus v. State

500 So. 2d 1367, 12 Fla. L. Weekly 239

District Court of Appeal of Florida | Filed: Jan 6, 1987 | Docket: 1295072

Cited 23 times | Published

Wilds that "she didn't know anything," since Section 90.608(1), Florida Statutes (1983), allows a party

Austin v. State

461 So. 2d 1380

District Court of Appeal of Florida | Filed: Dec 17, 1984 | Docket: 464587

Cited 23 times | Published

Mincey's prior inconsistent statement under Section 90.608, Florida Statutes, which allows a party calling

Hannon v. State

638 So. 2d 39, 1994 WL 233896

Supreme Court of Florida | Filed: Jun 2, 1994 | Docket: 2452590

Cited 22 times | Published

was proper impeachment of Acker's testimony. § 90.608, Fla. Stat. (1991). Whether Acker had inquired

Murray v. State

838 So. 2d 1073, 2002 WL 31191035

Supreme Court of Florida | Filed: Oct 3, 2002 | Docket: 1513693

Cited 21 times | Published

on this basis was error. In relevant part, section 90.608(2), Florida Statutes (1999), states: "Any party

Washington v. State

737 So. 2d 1208, 1999 WL 534733

District Court of Appeal of Florida | Filed: Jul 27, 1999 | Docket: 1709666

Cited 21 times | Published

as testified to by the witness being impeached. § 90.608, Fla. Stat. (1997). This provision is a proper

Erp v. Carroll

438 So. 2d 31

District Court of Appeal of Florida | Filed: Aug 18, 1983 | Docket: 1731785

Cited 20 times | Published

topic of who may impeach is now provided in section 90.608, Florida Statutes (1981). Accordingly, consideration

Gelabert v. State

407 So. 2d 1007

District Court of Appeal of Florida | Filed: Dec 23, 1981 | Docket: 467510

Cited 20 times | Published

incorporated into the Florida Evidence Code in section 90.608, Florida Statutes (1979), which provides in

Dias v. State

812 So. 2d 487, 2002 WL 384970

District Court of Appeal of Florida | Filed: Mar 13, 2002 | Docket: 1364310

Cited 19 times | Published

offered to impeach Anna's testimony. See *495 § 90.608(1), Fla. Stat. (1999). A statement inadmissible

State v. Raydo

713 So. 2d 996, 1998 WL 333429

Supreme Court of Florida | Filed: Jun 25, 1998 | Docket: 1732753

Cited 19 times | Published

pursuant to section 90.610(1), but pursuant to section 90.608(2), Florida Statutes (1995). [7] We note the

Street v. State

636 So. 2d 1297, 1994 WL 102656

Supreme Court of Florida | Filed: Mar 31, 1994 | Docket: 1361455

Cited 19 times | Published

inconsistent deposition statement to impeach Rocco. See § 90.608(2), Fla. Stat. (1989);[6]Botte v. Pomeroy, 497

Bell v. State

491 So. 2d 537, 11 Fla. L. Weekly 322

Supreme Court of Florida | Filed: Jul 10, 1986 | Docket: 1383148

Cited 19 times | Published

Impeaching one's own witness is generally proscribed. § 90.608, Fla. Stat. (1981).

Jackson v. State

25 So. 3d 518, 34 Fla. L. Weekly Supp. 541, 2009 Fla. LEXIS 1577, 2009 WL 3029662

Supreme Court of Florida | Filed: Sep 24, 2009 | Docket: 1662100

Cited 17 times | Published

conviction was necessary to establish bias. Under section 90.608(2), Florida Statutes (2007), any party may

Gorham v. State

597 So. 2d 782, 1992 WL 49942

Supreme Court of Florida | Filed: Mar 19, 1992 | Docket: 1350981

Cited 15 times | Published

attacked by showing that the witness is biased. § 90.608(1)(b), Fla. Stat. (1981). A witness' relationship

Sloan v. State

472 So. 2d 488, 10 Fla. L. Weekly 1402

District Court of Appeal of Florida | Filed: Jun 7, 1985 | Docket: 1793462

Cited 15 times | Published

trial strategy, and found it not offensive to section 90.608, Florida Statutes. Affirmed. GRIMES, A.C.J

Dickey v. State

458 So. 2d 1156

District Court of Appeal of Florida | Filed: Nov 6, 1984 | Docket: 1733242

Cited 15 times | Published

was error to allow it to be impeached, see Section 90.608(1)(e), Florida Statutes, and 2) even if it

Pantoja v. State

59 So. 3d 1092, 36 Fla. L. Weekly Supp. 91, 2011 Fla. LEXIS 519, 2011 WL 722374

Supreme Court of Florida | Filed: Mar 3, 2011 | Docket: 60299563

Cited 14 times | Published

prior false accusation is admissible under section 90.608(2), Florida Statutes (2002), to prove bias

Dempsey v. Shell Oil Co.

589 So. 2d 373, 1991 WL 231855

District Court of Appeal of Florida | Filed: Nov 13, 1991 | Docket: 1441826

Cited 14 times | Published

Miami, 454 So.2d 681 (Fla. 3d DCA 1984). *377 Section 90.608, Fla.Evid. Code (1991) governs impeachment

Watson v. Builders Square, Inc.

563 So. 2d 721, 1990 WL 67303

District Court of Appeal of Florida | Filed: Jul 11, 1990 | Docket: 1281759

Cited 14 times | Published

5th DCA 1983): Notwithstanding that present section 90.608(2) eliminates the necessity of surprise in

Kingery v. State

523 So. 2d 1199, 1988 WL 27734

District Court of Appeal of Florida | Filed: Mar 30, 1988 | Docket: 472660

Cited 14 times | Published

proper only in very limited circumstances. Section 90.608(2), Florida Statutes, provides in part that

Rose v. State

472 So. 2d 1155, 10 Fla. L. Weekly 280

Supreme Court of Florida | Filed: May 16, 1985 | Docket: 1793614

Cited 14 times | Published

purpose of determining his credibility. However, section 90.608, Florida Statutes (1983), provides in part:

Ferere v. Shure

65 So. 3d 1141, 2011 Fla. App. LEXIS 11351, 2011 WL 2848578

District Court of Appeal of Florida | Filed: Jul 20, 2011 | Docket: 2363401

Cited 13 times | Published

to attack the gynecologist's credibility. See § 90.608(5), Fla. Stat. (2008) ("Any party ... may attack

Saleeby v. Rocky Elson Construction, Inc.

3 So. 3d 1078, 34 Fla. L. Weekly Supp. 106, 2009 Fla. LEXIS 147, 2009 WL 217974

Supreme Court of Florida | Filed: Jan 30, 2009 | Docket: 1653006

Cited 13 times | Published

John Herring by showing that he was biased. Section 90.608(2), Florida Statutes (2006), expressly authorizes

Jones v. State

678 So. 2d 890, 1996 WL 471145

District Court of Appeal of Florida | Filed: Aug 21, 1996 | Docket: 1736954

Cited 13 times | Published

bias, admissible under section 90.608(1)(b), Florida Statutes (1995). Section 90.608(1)(b), provides that

Garcia v. State

564 So. 2d 124, 1990 WL 82926

Supreme Court of Florida | Filed: Jun 14, 1990 | Docket: 1294627

Cited 13 times | Published

state's argument, and find reversible error. Section 90.608(1)(e) of the Florida Statutes (1981), provides

Gosciminski v. State

132 So. 3d 678, 38 Fla. L. Weekly Supp. 638, 2013 WL 5313183, 2013 Fla. LEXIS 1988

Supreme Court of Florida | Filed: Sep 12, 2013 | Docket: 60238539

Cited 12 times | Published

for attacking a witness’s credibility under section 90.608(2), Florida Statutes (2009), there must be

Strasser v. Yalamanchi

783 So. 2d 1087, 2001 WL 195056

District Court of Appeal of Florida | Filed: Feb 28, 2001 | Docket: 1259353

Cited 12 times | Published

purpose of attacking Parnell's credibility. Section 90.608, Florida Statutes, permits a party to attack

Robinson v. State

770 So. 2d 1167, 2000 WL 1473147

Supreme Court of Florida | Filed: Oct 5, 2000 | Docket: 1778818

Cited 12 times | Published

admissible on retrial as impeachment evidence under section 90.608, Florida Statutes (1997). See id. After recognizing

Wilcox v. State

143 So. 3d 359, 39 Fla. L. Weekly Supp. 309, 2014 WL 1809636, 2014 Fla. LEXIS 1557

Supreme Court of Florida | Filed: May 8, 2014 | Docket: 60242309

Cited 11 times | Published

a prior inconsistent statement pursuant to section 90.608, Florida Statutes (2008), the prior statement

Childers v. State

936 So. 2d 585, 2006 WL 2620262

District Court of Appeal of Florida | Filed: Feb 2, 2006 | Docket: 109021

Cited 11 times | Published

credibility by "showing that a witness is biased." § 90.608(2), Fla. Stat. (2002). The relevancy standards

Smith v. State

880 So. 2d 730, 2004 WL 1175488

District Court of Appeal of Florida | Filed: May 28, 2004 | Docket: 1295016

Cited 11 times | Published

purposes only and not as substantive evidence. See § 90.608(1); Delgado-Santos, 497 So.2d 1199; Ivery, 548

Hinojosa v. State

857 So. 2d 308, 2003 WL 22316817

District Court of Appeal of Florida | Filed: Oct 10, 2003 | Docket: 1774227

Cited 11 times | Published

State, 798 So.2d 870 (Fla. 4th DCA 2001). Section 90.608(2), Florida Statutes (2001), provides that

Bush v. State

809 So. 2d 107, 2002 WL 341790

District Court of Appeal of Florida | Filed: Mar 6, 2002 | Docket: 1722365

Cited 11 times | Published

removed from the Bush home. We find no error. Section 90.608(5), Florida Statutes (1999), states that any

Cohen v. Dauphinee

739 So. 2d 68, 1999 WL 236248

Supreme Court of Florida | Filed: Apr 15, 1999 | Docket: 1293999

Cited 11 times | Published

him-a practice permitted and encouraged by section 90.608, Florida Statutes (1997). Accordingly, absent

Williams v. State

560 So. 2d 1304, 1990 WL 52797

District Court of Appeal of Florida | Filed: Apr 27, 1990 | Docket: 1739530

Cited 11 times | Published

section to be used to avoid the provision of section 90.608(1) that prohibits a party from impeaching his

Tumblin v. State

29 So. 3d 1093, 35 Fla. L. Weekly Supp. 133, 2010 Fla. LEXIS 258, 2010 WL 652982

Supreme Court of Florida | Filed: Feb 25, 2010 | Docket: 1643471

Cited 10 times | Published

witness’s ability to observe, remember, and recount); § 90.608(4), Fla. Stat. (2009) (any party may attack the

Jordan Ex Rel. Shealey v. Masters

821 So. 2d 342, 2002 WL 1332002

District Court of Appeal of Florida | Filed: Jun 19, 2002 | Docket: 2558502

Cited 10 times | Published

credibility of Dr. Sullivan was improper impeachment. Section 90.608, Florida Statutes (1997), provides the means

Slocum v. State

757 So. 2d 1246, 2000 WL 561717

District Court of Appeal of Florida | Filed: May 10, 2000 | Docket: 1331499

Cited 10 times | Published

broad categories of impeachment contained in section 90.608, Florida Statutes (1999). The crux of the trial

Purcell v. State

735 So. 2d 579, 1999 WL 414928

District Court of Appeal of Florida | Filed: Jun 23, 1999 | Docket: 1431036

Cited 10 times | Published

witness had nothing to "let go away."[2] Under section 90.608(2), any party may attack the credibility of

Livingston v. State

678 So. 2d 895, 1996 WL 471155

District Court of Appeal of Florida | Filed: Aug 21, 1996 | Docket: 1737015

Cited 10 times | Published

as evidence of bias or interest pursuant to section 90.608(2), Florida Statutes (1995). All witnesses

Botte v. Pomeroy

497 So. 2d 1275, 11 Fla. L. Weekly 2363

District Court of Appeal of Florida | Filed: Nov 12, 1986 | Docket: 1242857

Cited 10 times | Published

inconsistent deposition testimony as impeachment. See § 90.608(2), Fla. Stat. (1983). Although Edwards' employee

Del Monte Banana Co. v. Chacon

466 So. 2d 1167, 10 Fla. L. Weekly 882

District Court of Appeal of Florida | Filed: Apr 2, 1985 | Docket: 1525003

Cited 10 times | Published

Alvarez v. Mauney, 175 So.2d 57 (Fla. 2d DCA 1965); § 90.608(1)(b), Fla. Stat. (1983); 24 Fla.Jur.2d Evidence

Federal Deposit Ins. Corp. v. Carre

436 So. 2d 227

District Court of Appeal of Florida | Filed: Jul 1, 1983 | Docket: 1339920

Cited 10 times | Published

been admitted to impeach Mr. Carre pursuant to section 90.608(1)(e), Florida Statutes (1981). Mr. Carre argues

Starchk v. Wittenberg

411 So. 2d 1000

District Court of Appeal of Florida | Filed: Mar 31, 1982 | Docket: 1696889

Cited 10 times | Published

Regulation which had called her as a witness. § 90.608, Fla. Stat. (1979). See also Gelabert v. State

Curtis v. State

876 So. 2d 13, 2004 WL 1091144

District Court of Appeal of Florida | Filed: May 18, 2004 | Docket: 1245463

Cited 9 times | Published

the party calling the witness," pursuant to section 90.608, Florida Statutes, it is still improper under

State v. Richards

843 So. 2d 962, 2003 WL 1916693

District Court of Appeal of Florida | Filed: Apr 23, 2003 | Docket: 1243910

Cited 9 times | Published

a party is allowed to impeach its own witness. § 90.608, Fla. Stat. (2001). Standing alone, this provision

Chadwick v. State

680 So. 2d 567, 21 Fla. L. Weekly Fed. D 1791

District Court of Appeal of Florida | Filed: Aug 7, 1996 | Docket: 1201479

Cited 9 times | Published

to show the bias of prosecution witnesses. See § 90.608(2), Fla. Stat. (1993); see also Diaz v. State

Logan v. State

592 So. 2d 295, 1991 WL 268554

District Court of Appeal of Florida | Filed: Dec 19, 1991 | Docket: 1429511

Cited 9 times | Published

defendant himself, and in light of the amendment to section 90.608, Florida Statutes (Supp. 1990). [4] It is

Lusk v. State

531 So. 2d 1377, 1988 WL 99738

District Court of Appeal of Florida | Filed: Sep 30, 1988 | Docket: 544137

Cited 9 times | Published

Watts v. State, 450 So.2d 265 (Fla.2d DCA 1984); § 90.608, Fla. Stat. (1985). In summary, we find that the

Hair v. State

428 So. 2d 760

District Court of Appeal of Florida | Filed: Mar 29, 1983 | Docket: 2527182

Cited 9 times | Published

by introducing testimony of other witnesses. Section 90.608, Florida Statutes (1979) provides, in pertinent

Smith v. State

404 So. 2d 167

District Court of Appeal of Florida | Filed: Sep 29, 1981 | Docket: 1782317

Cited 9 times | Published

credibility may be attacked by a showing of bias, § 90.608(1)(b), Florida Statutes, although both the Code

Agatheas v. State

77 So. 3d 1232, 36 Fla. L. Weekly Supp. 741, 2011 Fla. LEXIS 2880, 2011 WL 6220761

Supreme Court of Florida | Filed: Dec 15, 2011 | Docket: 60304655

Cited 8 times | Published

raise questions about his or her credibility. Section 90.608, Florida Statutes (2006), specifies the permissible

City of Orlando v. Pineiro

66 So. 3d 1064, 2011 Fla. App. LEXIS 12266, 2011 WL 3359613

District Court of Appeal of Florida | Filed: Aug 5, 2011 | Docket: 2363235

Cited 8 times | Published

Department. The City asserted that, pursuant to section 90.608, Florida Statutes (2009), evidence of these

Hunter v. State

29 So. 3d 256, 33 Fla. L. Weekly Supp. 721, 2008 Fla. LEXIS 1636, 2008 WL 4348485

Supreme Court of Florida | Filed: Sep 25, 2008 | Docket: 2410965

Cited 8 times | Published

statements given at Hunter's original trial. See § 90.608(1), Fla. Stat. (2007). In light of the strong

Billie v. State

863 So. 2d 323, 2003 WL 21749078

District Court of Appeal of Florida | Filed: Jul 30, 2003 | Docket: 1432231

Cited 8 times | Published

added). Cf. § 90.404(1)(a) & (c), Fla. Stat.; § 90.608(5), Fla. Stat. Billie also claims on appeal that

Barows v. State

805 So. 2d 120, 2002 WL 84253

District Court of Appeal of Florida | Filed: Jan 23, 2002 | Docket: 1669696

Cited 8 times | Published

was relevant to show bias or motive to lie. Section 90.608(2), Florida Statutes, as well as the Sixth

Flores v. Miami-Dade County

787 So. 2d 955, 2001 Fla. App. LEXIS 8068, 26 Fla. L. Weekly Fed. D 1471

District Court of Appeal of Florida | Filed: Jun 13, 2001 | Docket: 1745004

Cited 8 times | Published

the credibility of a lay witness specified in section 90.608 may be used to attack the credibility of an

James v. State

765 So. 2d 763, 2000 WL 815667

District Court of Appeal of Florida | Filed: Jun 26, 2000 | Docket: 428969

Cited 8 times | Published

the testimony of Brown as evidence of guilt. Section 90.608(1), Florida Statutes (1997), provides that:

McBean v. State

688 So. 2d 383, 1997 WL 43380

District Court of Appeal of Florida | Filed: Feb 5, 1997 | Docket: 1508297

Cited 8 times | Published

material and would naturally have been mentioned. § 90.608(1), Fla. Stat. (1995). See State v. Smith, 573

Dudley v. State

545 So. 2d 857, 1989 WL 65508

Supreme Court of Florida | Filed: Jun 15, 1989 | Docket: 1345717

Cited 8 times | Published

constitute adverse testimony as contemplated by section 90.608(2). As explained in Austin v. State, 461 So

Edwards v. State

530 So. 2d 936, 1988 WL 70662

District Court of Appeal of Florida | Filed: Jul 13, 1988 | Docket: 1678381

Cited 8 times | Published

Cruz v. State, 437 So.2d 692 (Fla. 1st DCA 1983); § 90.608(1)(d), Fla. Stat. (1985). This latitude has been

Hernandez v. CHARLES E. VIRGIN, MD, PA

505 So. 2d 1369, 12 Fla. L. Weekly 1031

District Court of Appeal of Florida | Filed: Apr 14, 1987 | Docket: 1454692

Cited 8 times | Published

be used for impeachment purposes at trial. Section 90.608(1)(a), Florida Statutes (1985), provides that

Thornes v. State

485 So. 2d 1357, 11 Fla. L. Weekly 757

District Court of Appeal of Florida | Filed: Apr 1, 1986 | Docket: 1276003

Cited 8 times | Published

to admit Mrs. Thornes' proffered testimony. Section 90.608(1)(a), Florida Statutes (1983), recognizes

Marrero v. State

478 So. 2d 1155, 10 Fla. L. Weekly 2613

District Court of Appeal of Florida | Filed: Nov 26, 1985 | Docket: 1331970

Cited 8 times | Published

with the witness's *1156 present testimony. See § 90.608(1)(a), Fla. Stat. (1983). The law of evidence

Cruz v. State

437 So. 2d 692

District Court of Appeal of Florida | Filed: Apr 14, 1983 | Docket: 1675073

Cited 8 times | Published

recount the matters about which he testified." § 90.608(1)(d), Fla. Stat. (1981). Florida jurisprudence

Rodney Tyrone Lowe v. State of Florida

259 So. 3d 23

Supreme Court of Florida | Filed: Oct 19, 2018 | Docket: 8065908

Cited 7 times | Published

a prior inconsistent statement pursuant to section 90.608, Florida Statutes (2008), the *44prior statement

Love v. State

971 So. 2d 280, 2008 WL 80223

District Court of Appeal of Florida | Filed: Jan 9, 2008 | Docket: 1731987

Cited 7 times | Published

since such testimony was admissible under section 90.608(1)(b), Florida Statutes (1996). To introduce

Williamson v. State

961 So. 2d 229, 2007 WL 1362872

Supreme Court of Florida | Filed: May 10, 2007 | Docket: 1515799

Cited 7 times | Published

Sanchez-Velasco affidavit could be introduced under section 90.608, Florida Statutes (2006), to impeach Baez through

Roebuck v. State

953 So. 2d 40, 2007 WL 934889

District Court of Appeal of Florida | Filed: Mar 30, 2007 | Docket: 1315199

Cited 7 times | Published

(1) to establish bias or motive pursuant to section 90.608(2) Florida Statutes; or (2) when character

Mitchell v. State

862 So. 2d 908, 2003 WL 23008794

District Court of Appeal of Florida | Filed: Dec 24, 2003 | Docket: 1762928

Cited 7 times | Published

relationship with Robinson or the appellant. Section 90.608(2), Florida Statutes, as well as the Sixth

Williams v. State

689 So. 2d 393, 1997 WL 90815

District Court of Appeal of Florida | Filed: Mar 5, 1997 | Docket: 1739301

Cited 7 times | Published

observation of the entire traumatic event. See § 90.608(4), Fla. Stat. (1995). Accordingly, we hold that

Solis v. Calvo

689 So. 2d 366, 1997 WL 65857

District Court of Appeal of Florida | Filed: Feb 19, 1997 | Docket: 1739247

Cited 7 times | Published

raised by the appellant to be without merit. See § 90.608(1), Fla.Stat. (1995); Gibson v. State, 661 So

Jackson v. State

603 So. 2d 670, 1992 WL 191308

District Court of Appeal of Florida | Filed: Aug 12, 1992 | Docket: 68599

Cited 7 times | Published

to attack the credibility of a witness. See section 90.608(1), Florida Statutes (Supp. 1990). Reversed

Michaels v. State

429 So. 2d 338

District Court of Appeal of Florida | Filed: Mar 4, 1983 | Docket: 1221737

Cited 7 times | Published

that party unless the witness proves adverse. § 90.608(2), Fla. Stat. (1981); Johnson v. State, 178 So

Nationwide Mut. Fire Ins. Co. v. Bruscarino

982 So. 2d 753, 2008 WL 2261544

District Court of Appeal of Florida | Filed: Jun 4, 2008 | Docket: 1208746

Cited 6 times | Published

impermissible." Id. at 1108. In doing so, we noted that section 90.608, Florida Statutes, permits the credibility

Sanchez v. Nerys

954 So. 2d 630, 2007 WL 466031

District Court of Appeal of Florida | Filed: Feb 14, 2007 | Docket: 1651684

Cited 6 times | Published

partiality, improper relationships or motives. § 90.608, Fla. Stat. (2005); § 90.702, Fla. Stat. (2005)

Pardo v. State

941 So. 2d 1057, 2006 WL 1766755

Supreme Court of Florida | Filed: Oct 19, 2006 | Docket: 1523621

Cited 6 times | Published

an attack on the credibility of a witness. See § 90.608, Fla. Stat. (2005). The validity of an affidavit

Rowley v. State

939 So. 2d 298, 2006 WL 2956514

District Court of Appeal of Florida | Filed: Oct 18, 2006 | Docket: 2533136

Cited 6 times | Published

rescue its position. Slocum did indeed read section 90.608 to exclude cross examination of a police officer

Jackson v. State

881 So. 2d 711, 2004 WL 2026790

District Court of Appeal of Florida | Filed: Sep 9, 2004 | Docket: 712517

Cited 6 times | Published

prior testimony at his pretrial deposition. See § 90.608(1), Fla. Stat. (2002).[1] We conclude that the

Rockerman v. State

773 So. 2d 602, 2000 Fla. App. LEXIS 15914, 2000 WL 1780744

District Court of Appeal of Florida | Filed: Dec 6, 2000 | Docket: 64802429

Cited 6 times | Published

them to limit their testimony accordingly. See § 90.608(l)(a), Fla. Stat. (1999); see generally Charles

Claussen v. STATE, DEPT. OF TRANSP.

750 So. 2d 79, 1999 Fla. App. LEXIS 15714, 1999 WL 1075099

District Court of Appeal of Florida | Filed: Dec 1, 1999 | Docket: 1432735

Cited 6 times | Published

the letter was proper impeachment evidence. Section 90.608, Florida Statutes (1997), identifies who may

Mosley v. State

616 So. 2d 1129, 1993 WL 107980

District Court of Appeal of Florida | Filed: Apr 13, 1993 | Docket: 1367662

Cited 6 times | Published

elicit testimony showing the bias of a witness. See § 90.608(2), Fla. Stat. (1991); Breedlove v. State, 580

Calhoun v. State

502 So. 2d 1364, 12 Fla. L. Weekly 644

District Court of Appeal of Florida | Filed: Feb 27, 1987 | Docket: 1181031

Cited 6 times | Published

to have been made justifying application of section 90.608(1)(a), Florida Statutes (1985), of the evidence

Gamble v. State

492 So. 2d 1132, 11 Fla. L. Weekly 1724

District Court of Appeal of Florida | Filed: Aug 7, 1986 | Docket: 1518653

Cited 6 times | Published

[1] § 794.011(4)(b), Fla. Stat. (1983). [2] § 90.608(1)(a), Fla. Stat. (1983); 90.614(2), Fla. Stat

Williams v. State

472 So. 2d 1350, 10 Fla. L. Weekly 1816

District Court of Appeal of Florida | Filed: Jul 24, 1985 | Docket: 1793752

Cited 6 times | Published

that are inconsistent with his present testimony. § 90.608(1)(a), Fla. Stat. (1983). The prior inconsistent

Bell v. State

473 So. 2d 734, 10 Fla. L. Weekly 1396

District Court of Appeal of Florida | Filed: Jun 7, 1985 | Docket: 451698

Cited 6 times | Published

the prosecutor's interrogation of McBride to section 90.608, Florida Statutes, asserting that the questions

Jones v. State

452 So. 2d 643

District Court of Appeal of Florida | Filed: Jun 27, 1984 | Docket: 665498

Cited 6 times | Published

an adverse witness. This was clearly error. See § 90.608(2), Fla. Stat. (1983). See also Pitts v. State

Gross Builders, Inc. v. Powell

441 So. 2d 1142

District Court of Appeal of Florida | Filed: Nov 9, 1983 | Docket: 1333465

Cited 6 times | Published

usually, one may not impeach his own witness. § 90.608(2), Fla. Stat. (1981). We are satisfied, however

McNeil v. State

433 So. 2d 1294

District Court of Appeal of Florida | Filed: Jun 30, 1983 | Docket: 1727668

Cited 6 times | Published

state could impeach him if he testified adversely. § 90.608, Florida Statutes. Defense counsel objected to

Carlisle v. State

137 So. 3d 479, 2014 WL 1225200, 2014 Fla. App. LEXIS 4362

District Court of Appeal of Florida | Filed: Mar 26, 2014 | Docket: 60240329

Cited 5 times | Published

admissibility of the prior false accusation under section 90.608, Florida Statutes (showing the witness is biased)

Carnival Corp. v. Jimenez

112 So. 3d 513, 2013 WL 692647, 2013 Fla. App. LEXIS 3173

District Court of Appeal of Florida | Filed: Feb 27, 2013 | Docket: 60231131

Cited 5 times | Published

that he was biased in favor of Ms. Jimenez. See § 90.608(2), Fla. Stat. (2011); Steinger, Iscoe & Greene

Peterson v. State

24 So. 3d 686, 2009 Fla. App. LEXIS 19772, 2009 WL 4877693

District Court of Appeal of Florida | Filed: Dec 18, 2009 | Docket: 1152636

Cited 5 times | Published

attacked by showing that the witness is biased. § 90.608(2), Fla. Stat. (2008). A criminal defendant has

Baucham v. State

881 So. 2d 95, 2004 WL 1877555

District Court of Appeal of Florida | Filed: Aug 24, 2004 | Docket: 1466193

Cited 5 times | Published

testimony concerns facts not otherwise germane. See § 90.608, Fla. Stat. (2002) ("Any party, including the

Smith v. State

762 So. 2d 929, 2000 WL 526083

District Court of Appeal of Florida | Filed: May 3, 2000 | Docket: 1311495

Cited 5 times | Published

does not appear that the witness was misled. [8] § 90.608(1), Fla. Stat.

Czubak v. State

644 So. 2d 93, 1994 WL 470329

District Court of Appeal of Florida | Filed: Sep 2, 1994 | Docket: 1672239

Cited 5 times | Published

trial was attempting to impeach Ragsdale under section 90.608, Florida Statutes (1990), by offering the witnesses

Duncan v. State

450 So. 2d 242

District Court of Appeal of Florida | Filed: Apr 13, 1984 | Docket: 1729137

Cited 5 times | Published

recount the matters about which he testified." § 90.608(1)(d), Florida Statutes (1981). We concluded that

Mazzara v. State

437 So. 2d 716

District Court of Appeal of Florida | Filed: Aug 26, 1983 | Docket: 1675129

Cited 5 times | Published

inconsistent Michigan statement as set forth in Section 90.608(2), Florida Statutes (1981). Appellant contends

Landrum v. State

430 So. 2d 549

District Court of Appeal of Florida | Filed: Apr 29, 1983 | Docket: 446017

Cited 5 times | Published

impeachment purposes under the Florida Evidence Code, section 90.608, Florida Statutes (1981). However, section

Holley v. State

48 So. 3d 916, 2010 Fla. App. LEXIS 17659, 2010 WL 4628518

District Court of Appeal of Florida | Filed: Nov 17, 2010 | Docket: 60296647

Cited 4 times | Published

by ... [s]howing that the witness is biased.” § 90.608(2),. Fla. Stat. (2008). A party has the right

Espinoza v. State

37 So. 3d 387, 2010 Fla. App. LEXIS 8200, 2010 WL 2292150

District Court of Appeal of Florida | Filed: Jun 9, 2010 | Docket: 1240820

Cited 4 times | Published

method to attack the credibility of a witness. § 90.608(1), Fla. Stat. (2008). The theory of admissibility

Hernandez v. State

31 So. 3d 873, 2010 Fla. App. LEXIS 3342, 2010 WL 934029

District Court of Appeal of Florida | Filed: Mar 17, 2010 | Docket: 1647640

Cited 4 times | Published

the tape did not refresh her recollection. Section 90.608(1), Florida Statutes, states that "[a]ny party

DML v. State

976 So. 2d 670, 2008 WL 724024

District Court of Appeal of Florida | Filed: Mar 19, 2008 | Docket: 1274879

Cited 4 times | Published

have cast doubt on Brianna's credibility. See § 90.608(5), Fla. Stat. (2006) (providing that the credibility

Williams v. State

912 So. 2d 66, 2005 WL 2373905

District Court of Appeal of Florida | Filed: Sep 28, 2005 | Docket: 1755685

Cited 4 times | Published

initial report of the incident to the police. Section 90.608(2), Florida Statutes (2004), provides that

General Motors Corp. v. McGee

837 So. 2d 1010

District Court of Appeal of Florida | Filed: Mar 5, 2003 | Docket: 1527516

Cited 4 times | Published

impeachment recognized by the evidence code. See § 90.608, Fla. Stat. (2001). A witness cannot be impeached

Shaw v. State

831 So. 2d 772, 2002 WL 31696687

District Court of Appeal of Florida | Filed: Dec 4, 2002 | Docket: 1387655

Cited 4 times | Published

showing the bias of prosecution witnesses. See § 90.608(2), Fla. Stat. (2000) *774 ("Any party...may attack

Bateson v. State

761 So. 2d 1165, 2000 WL 726348

District Court of Appeal of Florida | Filed: Jun 7, 2000 | Docket: 1299955

Cited 4 times | Published

to call Vicky Cash to testify in the trial. Section 90.608(1), Florida Statutes, provides Any party, including

Davis v. State

756 So. 2d 205, 2000 WL 390300

District Court of Appeal of Florida | Filed: Apr 19, 2000 | Docket: 471150

Cited 4 times | Published

reversal and a new trial. Florida Statutes section 90.608(1) provides that a party may attack the credibility

Smith v. State

754 So. 2d 54, 2000 WL 159063

District Court of Appeal of Florida | Filed: Feb 16, 2000 | Docket: 431382

Cited 4 times | Published

of this statement to impeach was improper. Section 90.608, Florida Statutes (1999), sets out who may

Grant v. State

738 So. 2d 1020, 1999 WL 625364

District Court of Appeal of Florida | Filed: Aug 18, 1999 | Docket: 1752349

Cited 4 times | Published

Grant's supposedly incriminating conduct. See § 90.608(4), Fla. Stat. (1997). Grant was well aware of

Sanjurjo v. State

736 So. 2d 1263, 1999 WL 493914

District Court of Appeal of Florida | Filed: Jul 14, 1999 | Docket: 1429456

Cited 4 times | Published

sustained the "negative impeachment" objection. Section 90.608(1)(a), Florida Statutes (1997) recognizes the

CM v. State

698 So. 2d 1306, 1997 WL 530555

District Court of Appeal of Florida | Filed: Aug 27, 1997 | Docket: 1524316

Cited 4 times | Published

Oil Co., 589 So.2d 373 (Fla. 4th DCA 1991). Section 90.608(5), Florida Statutes (1995), allows impeachment

Correia v. State

654 So. 2d 952, 1995 WL 144144

District Court of Appeal of Florida | Filed: Apr 5, 1995 | Docket: 1303742

Cited 4 times | Published

form of the testimony of other witnesses. See § 90.608(5), Fla. Stat. (1991). Notwithstanding the collateral

Everett v. State

530 So. 2d 413, 1988 WL 86578

District Court of Appeal of Florida | Filed: Aug 24, 1988 | Docket: 1267681

Cited 4 times | Published

statute [§ 1101 Rev.Stat.Fla. (1892), precursor to § 90.608(2), Fla. Stat. (1979)], a party producing a witness

Irons v. State

498 So. 2d 958, 11 Fla. L. Weekly 2450

District Court of Appeal of Florida | Filed: Sep 3, 1986 | Docket: 1335602

Cited 4 times | Published

impeach Jolly by prior inconsistent statements. § 90.608(1)(a), Fla. Stat. (1985). However, as presented

Dukes v. State

442 So. 2d 316

District Court of Appeal of Florida | Filed: Dec 2, 1983 | Docket: 1515890

Cited 4 times | Published

attacked by showing that the witness is biased. § 90.608(1)(b), Fla. Stat. (1981). As this court stated

Elmer v. State

114 So. 3d 198, 2012 WL 4838884, 2012 Fla. App. LEXIS 17748

District Court of Appeal of Florida | Filed: Oct 12, 2012 | Docket: 60231795

Cited 3 times | Published

688 So.2d 383, 384 (Fla. 4th DCA 1997); see also § 90.608(1), Fla. Stat. (2010). In Pearce v. State, 880

Bearden v. State

62 So. 3d 656, 2011 Fla. App. LEXIS 5184, 2011 WL 1376974

District Court of Appeal of Florida | Filed: Apr 13, 2011 | Docket: 2361614

Cited 3 times | Published

affirmatively harmful testimony.” Id.; see also § 90.608, Fla. Stat. (2008) (“Any party, including the

Roosevelt v. State

42 So. 3d 293, 2010 Fla. App. LEXIS 11282, 2010 WL 3023314

District Court of Appeal of Florida | Filed: Aug 4, 2010 | Docket: 1647433

Cited 3 times | Published

by ... (2) Showing that the witness is biased.” § 90.608(2), Fla. Stat. (2008). We are unable to see any

Pulcini v. State

41 So. 3d 338, 2010 Fla. App. LEXIS 10569, 2010 WL 2882466

District Court of Appeal of Florida | Filed: Jul 21, 2010 | Docket: 2399257

Cited 3 times | Published

may be by leading questions." In addition, section 90.608(1), Florida Statutes, states that "[a]ny party

Childers v. Floyd

625 F.3d 1319

Court of Appeals for the Eleventh Circuit | Filed: Jun 8, 2010 | Docket: 1544438

Cited 3 times | Published

Constitution, Fla. Const. art I, § 16, Fla. Stat. § 90.608, and Florida case law.[7] The denial occurred

Ruff v. State

31 So. 3d 833, 2010 Fla. App. LEXIS 1607, 2010 WL 532790

District Court of Appeal of Florida | Filed: Feb 17, 2010 | Docket: 1150646

Cited 3 times | Published

was to impeach her with her prior statements. Section 90.608(1), Florida Statutes, states that "[a]ny party

Ocasio v. State

994 So. 2d 1258, 2008 WL 5156626

District Court of Appeal of Florida | Filed: Dec 10, 2008 | Docket: 1666686

Cited 3 times | Published

State, 798 So.2d 870, 874 (Fla. 4th DCA 2001). Section 90.608, Florida Statutes, permits "[a]ny party, including

Pantoja v. State

990 So. 2d 626, 2008 WL 4073348

District Court of Appeal of Florida | Filed: Sep 4, 2008 | Docket: 1293249

Cited 3 times | Published

a means not listed in section 90.608, Florida Statutes (1983)). Section 90.608 provides a complete list

Martino v. State

964 So. 2d 906, 2007 WL 2847942

District Court of Appeal of Florida | Filed: Oct 3, 2007 | Docket: 1264314

Cited 3 times | Published

v. State, 596 So.2d 1034, 1035 (Fla.1992)). Section 90.608(2), Florida Statutes, permits cross-examination

Minus v. State

901 So. 2d 344, 2005 WL 1030127

District Court of Appeal of Florida | Filed: May 4, 2005 | Docket: 1666218

Cited 3 times | Published

impeachment with a prior inconsistent statement. See § 90.608(1), Fla. Stat. (2001). In her letter to the judge

Robertson v. State

780 So. 2d 106, 2001 WL 293156

District Court of Appeal of Florida | Filed: Mar 28, 2001 | Docket: 1708605

Cited 3 times | Published

regarding the prior incident. Florida Statute Section 90.608(5), provides that once a defendant takes the

Collins v. State

698 So. 2d 1337, 1997 WL 564209

District Court of Appeal of Florida | Filed: Sep 12, 1997 | Docket: 1524249

Cited 3 times | Published

Collins as an "uncaring, unloving person." Section 90.608(1), Florida Statutes (1993), permits any party

Doremus v. Florida Energy Systems

634 So. 2d 1106, 1994 WL 112250

District Court of Appeal of Florida | Filed: Apr 6, 1994 | Docket: 1737606

Cited 3 times | Published

This court reversed for a new trial, citing section 90.608, Fla.Evid. Code (1991) (the credibility of

Hahn v. State

626 So. 2d 1056, 1993 WL 458975

District Court of Appeal of Florida | Filed: Nov 10, 1993 | Docket: 1684994

Cited 3 times | Published

the bias of the witness in accordance with section 90.608(1)(b), Florida Statutes, whether the witness

Nelson v. State

602 So. 2d 550, 1992 WL 9702

District Court of Appeal of Florida | Filed: Jan 24, 1992 | Docket: 1321422

Cited 3 times | Published

attempting to impeach McKenzie. We find, pursuant to section 90.608, Florida Statutes (1989), and the authorities

Abbott v. State

589 So. 2d 943, 1991 WL 203123

District Court of Appeal of Florida | Filed: Oct 11, 1991 | Docket: 1730705

Cited 3 times | Published

prior inconsistent statement she had made. See § 90.608(1)(a). Defendant's conviction for resisting an

Darley v. Marquee Enterprises, Inc.

565 So. 2d 715, 1990 WL 67299

District Court of Appeal of Florida | Filed: May 23, 1990 | Docket: 1403849

Cited 3 times | Published

this witness declared adverse on the basis of section 90.608(2), Florida Statutes (1989) and, therefore

Kimble v. State

537 So. 2d 1094, 1989 WL 5255

District Court of Appeal of Florida | Filed: Jan 27, 1989 | Docket: 427065

Cited 3 times | Published

which are inconsistent with his present testimony. § 90.608(1)(a), Fla. Stat. (1987). The Florida Evidence

Price v. State

469 So. 2d 210, 10 Fla. L. Weekly 1292

District Court of Appeal of Florida | Filed: May 23, 1985 | Docket: 1272084

Cited 3 times | Published

C.J., and ORFINGER, J., concur. NOTES [1] Section 90.608(1)(a), Florida Statutes, provides that "any

GEORGE GOMILLION v. STATE OF FLORIDA

267 So. 3d 502

District Court of Appeal of Florida | Filed: Mar 20, 2019 | Docket: 14752814

Cited 2 times | Published

recount the events of the evening in question. See § 90.608(4), Fla. Stat. (2016); Edwards v. State, 548

Billy Joe Pitts v. State of Florida

227 So. 3d 674, 2017 WL 3428273

District Court of Appeal of Florida | Filed: Aug 10, 2017 | Docket: 6135908

Cited 2 times | Published

former girlfriend’s testimony. ’See § 90.608(1), Fla. Stat. (2015) (providing that' any party

Vazquez v. Martinez

175 So. 3d 372, 2015 Fla. App. LEXIS 13895, 2015 WL 5456871

District Court of Appeal of Florida | Filed: Sep 18, 2015 | Docket: 60250556

Cited 2 times | Published

credibility ' of a witness by exposing a potential bias. § 90.608(2),, Fla. Stat. (2013). ■ “A jury is entitled

Joseph Eli Bearden v. State of Florida

161 So. 3d 1257, 40 Fla. L. Weekly Supp. 208, 2015 Fla. LEXIS 800, 2015 WL 1724590

Supreme Court of Florida | Filed: Apr 16, 2015 | Docket: 2649968

Cited 2 times | Published

party calling the witness,” pursuant to section 90.608, Florida Statutes, it is still improper under

Mardis v. State

122 So. 3d 950, 2013 WL 5538781, 2013 Fla. App. LEXIS 15908

District Court of Appeal of Florida | Filed: Oct 9, 2013 | Docket: 60234820

Cited 2 times | Published

however, is limited by the rules of evidence. Id. Section 90.608(2), Florida Statutes (2009), allows a party

Mardis v. State

122 So. 3d 950, 2013 WL 5538781, 2013 Fla. App. LEXIS 15908

District Court of Appeal of Florida | Filed: Oct 9, 2013 | Docket: 60234820

Cited 2 times | Published

however, is limited by the rules of evidence. Id. Section 90.608(2), Florida Statutes (2009), allows a party

Alexander v. State

103 So. 3d 953, 2012 Fla. App. LEXIS 21384, 2012 WL 6170662

District Court of Appeal of Florida | Filed: Dec 12, 2012 | Docket: 60227268

Cited 2 times | Published

(Fla. 4th DCA 2010) (emphasis original) (quoting § 90.608(5), Fla. Stat. (2009)). The test for determining

Faust v. State

95 So. 3d 421, 2012 WL 3326337, 2012 Fla. App. LEXIS 13575

District Court of Appeal of Florida | Filed: Aug 15, 2012 | Docket: 60311230

Cited 2 times | Published

this statement was admissible as impeachment. Section 90.608(1), Florida Statutes, permits the impeachment

Harris v. Grunow

71 So. 3d 186, 2011 Fla. App. LEXIS 15285, 2011 WL 4467379

District Court of Appeal of Florida | Filed: Sep 28, 2011 | Docket: 2356331

Cited 2 times | Published

sarcastically dubbed him the "star witness"). Section 90.608 allowed counsel for the Harrises to impeach

Mordenti v. State

982 So. 2d 710, 2008 WL 465588

District Court of Appeal of Florida | Filed: Feb 22, 2008 | Docket: 1664239

Cited 2 times | Published

would be admissible as impeachment testimony. See § 90.608. I would therefore concur with Judge Harris that

PINTADO v. State

970 So. 2d 857, 2007 WL 3355092

District Court of Appeal of Florida | Filed: Nov 14, 2007 | Docket: 1323370

Cited 2 times | Published

inconsistent with the witness' trial testimony. § 90.608, Fla. Stat. (2006). Here, the defense sought to

Lloyd v. State

909 So. 2d 580, 2005 WL 2105263

District Court of Appeal of Florida | Filed: Sep 2, 2005 | Docket: 1199752

Cited 2 times | Published

involving the defendant and her son, John Jr. Section 90.608(2), Florida Statutes (2004), specifically permits

Griffin v. State

827 So. 2d 1098, 27 Fla. L. Weekly Fed. D 2286

District Court of Appeal of Florida | Filed: Oct 16, 2002 | Docket: 1360921

Cited 2 times | Published

impeach the victim's credibility pursuant to section 90.608(5), Florida Statutes (2001). Specifically,

Tobin v. Leland

804 So. 2d 390, 2001 WL 1190894

District Court of Appeal of Florida | Filed: Oct 3, 2001 | Docket: 1699489

Cited 2 times | Published

about which he wrote some years ago. Under section 90.608(2), any party may attack credibility by showing

Robertson v. State

780 So. 2d 94, 2000 WL 368468

District Court of Appeal of Florida | Filed: Apr 12, 2000 | Docket: 1708736

Cited 2 times | Published

to section 404(2)(a), the dissent relies on section 90.608(5), which reads as follows: Any party, including

O'NEIL v. Gilbert

625 So. 2d 982, 1993 WL 431594

District Court of Appeal of Florida | Filed: Oct 26, 1993 | Docket: 1517513

Cited 2 times | Published

reflecting upon his credibility in a particular case, § 90.608(2), Fla. Stat. (1991), the immigration issue does

Pottgen v. State

589 So. 2d 390, 1991 WL 239911

District Court of Appeal of Florida | Filed: Nov 13, 1991 | Docket: 232519

Cited 2 times | Published

which the state asserted was admissible under section 90.608(2), Florida Statutes. That statute provides:

David v. City of Jacksonville

534 So. 2d 784, 1988 WL 122615

District Court of Appeal of Florida | Filed: Nov 18, 1988 | Docket: 1707664

Cited 2 times | Published

credibility by prior inconsistent statements under section 90.608, Florida Statutes (1985). Nor is the testimony

DJG v. State

524 So. 2d 1024, 1987 WL 2633

District Court of Appeal of Florida | Filed: Dec 9, 1987 | Docket: 1340656

Cited 2 times | Published

existence of the charged conspiracy. Under section 90.608(1), Florida Statutes (1985), it is improper

State v. Hill

504 So. 2d 407

District Court of Appeal of Florida | Filed: Jan 7, 1987 | Docket: 453585

Cited 2 times | Published

is a recognized method of impeaching a witness. § 90.608(1)(a), Fla. Stat. (1985). In most instances, the

Howard v. State

397 So. 2d 997

District Court of Appeal of Florida | Filed: Apr 22, 1981 | Docket: 1706625

Cited 2 times | Published

provides that the admissibility of evidence under Section 90.608, Florida Statutes (1979) is not affected by

Rivera v. State

274 So. 3d 537

District Court of Appeal of Florida | Filed: Jun 21, 2019 | Docket: 64718356

Cited 1 times | Published

attack a witness's credibility based on bias. § 90.608(2), Fla. Stat. (2014) ("Any party, including the

Robert Roy Macomber v. State of Florida

254 So. 3d 1098

District Court of Appeal of Florida | Filed: Aug 30, 2018 | Docket: 7774961

Cited 1 times | Published

particular material issue in this case.” Section 90.608, Florida Statutes, provides that Appellant

Vincent J. Klaus v. State

236 So. 3d 483

District Court of Appeal of Florida | Filed: Jan 8, 2018 | Docket: 6262718

Cited 1 times | Published

Jarrett’s body had not been burned. Section 90.608(5), Florida Statutes (2010), states that any

John Sexton v. State of Florida

221 So. 3d 547, 42 Fla. L. Weekly Supp. 713, 2017 WL 2806993, 2017 Fla. LEXIS 1431

Supreme Court of Florida | Filed: Jun 29, 2017 | Docket: 6082145

Cited 1 times | Published

allowed to attack a witness’s credibility” under section 90.608, Florida Statutes (1987). Id. Moreover, “[i]f

Pedro Fajardo v. State of Florida

193 So. 3d 1019, 2016 WL 3176968, 2016 Fla. App. LEXIS 8824

District Court of Appeal of Florida | Filed: Jun 8, 2016 | Docket: 3071327

Cited 1 times | Published

3d 1092, 1099 (Fla.2011)); see also § 90.608(2), Fla. Stat. (2013) (“Any party, including the

& SC13-2330 Michael A. Hernandez, Jr. v. State of Florida and Michael A. Hernandez, Jr. v. Julie L. Jones, etc.

180 So. 3d 978, 2015 WL 5445655

Supreme Court of Florida | Filed: Sep 17, 2015 | Docket: 2816844

Cited 1 times | Published

the proper subject for impeachment ■ under section 90.608, Florida Statutes (2007). That' provision allows

Pierce v. State

137 So. 3d 578, 2014 Fla. App. LEXIS 6233, 2014 WL 1696141

District Court of Appeal of Florida | Filed: Apr 30, 2014 | Docket: 60240377

Cited 1 times | Published

purposes of impeaching the victim’s credibility. See § 90.608(1), Fla. Stat. (2001); Marshall v. State, 68 So

Anderson v. State

133 So. 3d 646, 2014 WL 996486, 2014 Fla. App. LEXIS 3600

District Court of Appeal of Florida | Filed: Mar 14, 2014 | Docket: 60238865

Cited 1 times | Published

State, 919 So.2d 647, 649 (Fla. 1st DCA 2006). Section 90.608(5), Florida Statutes (2011), provides that

Wyon Dale Childers v. Willie L. Floyd, Warden-Glades Correctional Institution

736 F.3d 1331, 2013 WL 6169275, 2013 U.S. App. LEXIS 23019

Court of Appeals for the Eleventh Circuit | Filed: Nov 14, 2013 | Docket: 142762

Cited 1 times | Published

to by the witness being impeached.” Fla. Stat. § 90.608. . In Van Arsdall, the Supreme Court likewise

Ware v. State

124 So. 3d 388, 2013 WL 5744445, 2013 Fla. App. LEXIS 16900

District Court of Appeal of Florida | Filed: Oct 23, 2013 | Docket: 60235471

Cited 1 times | Published

about the events of this alleged offense.” Section 90.608, Florida Statutes (2012), states that any party

Pack v. Geico General Insurance Co.

119 So. 3d 1284, 2013 WL 4727005, 2013 Fla. App. LEXIS 14098

District Court of Appeal of Florida | Filed: Sep 4, 2013 | Docket: 60233574

Cited 1 times | Published

of more serious injuries to her neck. Under Section 90.608(2), Florida Statutes (2009), any party may

Massey v. State

109 So. 3d 324, 2013 WL 1136404, 2013 Fla. App. LEXIS 4409

District Court of Appeal of Florida | Filed: Mar 20, 2013 | Docket: 60229567

Cited 1 times | Published

testified to by the witness being impeached.” § 90.608(5), Fla. Stat. (2010). Not finding the error in

Bleich v. State

108 So. 3d 1132, 2013 WL 1007636, 2013 Fla. App. LEXIS 4190

District Court of Appeal of Florida | Filed: Mar 15, 2013 | Docket: 60228991

Cited 1 times | Published

guilty of the robbery, and this appeal followed. Section 90.608(1), Florida Statutes (2010), provides that

Henry v. State

123 So. 3d 1167, 2013 WL 950045, 2013 Fla. App. LEXIS 3954

District Court of Appeal of Florida | Filed: Mar 13, 2013 | Docket: 60234886

Cited 1 times | Published

pending case were admissible to show bias under section 90.608(2), Florida Statutes (2010). “[T]he Sixth Amendment

Becker v. State

110 So. 3d 473, 2013 WL 811664, 2013 Fla. App. LEXIS 3532

District Court of Appeal of Florida | Filed: Mar 6, 2013 | Docket: 60230304

Cited 1 times | Published

by ... [s]howing that the witness is biased.” § 90.608(2), Fla. Stat. (2010). “Included in the types

Steinger, Iscoe & Greene, P.A. v. GEICO General Insurance Co.

103 So. 3d 200, 2012 Fla. App. LEXIS 20208, 2012 WL 5870041

District Court of Appeal of Florida | Filed: Nov 21, 2012 | Docket: 60227002

Cited 1 times | Published

attack a witness’s credibility based on bias. § 90.608(2), Fla. Stat. (2012). A treating physician, like

Smith v. State

98 So. 3d 632, 2012 WL 3822115, 2012 Fla. App. LEXIS 14855

District Court of Appeal of Florida | Filed: Sep 5, 2012 | Docket: 60312494

Cited 1 times | Published

testimony was the product of possible manipulation. Section 90.608(2), Florida Statutes (2009), allows a party

Woods v. State

92 So. 3d 890, 2012 WL 2913176, 2012 Fla. App. LEXIS 11674

District Court of Appeal of Florida | Filed: Jul 18, 2012 | Docket: 60310377

Cited 1 times | Published

inconsistent with the witness’s present testimony.” § 90.608(1), Fla. Stat. (2008). “The inconsistent statement

Maharaj v. State

78 So. 3d 63, 2012 Fla. App. LEXIS 530, 2012 WL 126105

District Court of Appeal of Florida | Filed: Jan 18, 2012 | Docket: 60305082

Cited 1 times | Published

1261 (Fla. 4th DCA 2008) (citation omitted). Section 90.608(5), Florida Statutes (2009), provides that

Wilson v. State

72 So. 3d 331, 2011 Fla. App. LEXIS 16898, 2011 WL 5061349

District Court of Appeal of Florida | Filed: Oct 26, 2011 | Docket: 2357815

Cited 1 times | Published

testified to by the witness being impeached." § 90.608(5), Fla. Stat. (2009) (emphasis added). "In determining

Marshall v. State

68 So. 3d 374, 2011 Fla. App. LEXIS 13494, 2011 WL 3754664

District Court of Appeal of Florida | Filed: Aug 26, 2011 | Docket: 2358812

Cited 1 times | Published

472 So.2d 1350, 1352 (Fla. 2d DCA 1985) (citing § 90.608(1)(a), Fla. Stat. (1983)). The prior inconsistent

B.M. v. State

66 So. 3d 1013, 2011 Fla. App. LEXIS 10563

District Court of Appeal of Florida | Filed: Jul 6, 2011 | Docket: 60301807

Cited 1 times | Published

to show the bias of prosecution witnesses. See § 90.608(2), Fla. Stat. (1993); see also Diaz v. State

Tripoli v. State

50 So. 3d 776, 2010 Fla. App. LEXIS 19854, 2010 WL 5346445

District Court of Appeal of Florida | Filed: Dec 29, 2010 | Docket: 60297351

Cited 1 times | Published

be inadmissible under section 90.608(5), Florida Statutes (2008). “Section 90.608(5) provides that any

Smith v. State

990 So. 2d 1199, 2008 WL 4265338

District Court of Appeal of Florida | Filed: Sep 19, 2008 | Docket: 1688350

Cited 1 times | Published

identification testimony of Lee Keith and Tommy Whitmer. § 90.608, Fla. Stat. (2008).[4] If the trier of fact was

D.M.L. v. State

976 So. 2d 670, 2008 Fla. App. LEXIS 3868

District Court of Appeal of Florida | Filed: Mar 19, 2008 | Docket: 64854100

Cited 1 times | Published

have cast doubt on Brianna’s credibility. See § 90.608(5), Fla. Stat. (2006) (providing that the credibility

Welch v. State

940 So. 2d 1244, 2006 WL 3103152

District Court of Appeal of Florida | Filed: Nov 3, 2006 | Docket: 1523873

Cited 1 times | Published

witness, as provided in ss. 90.608-90.610. Section 90.608 deals with "[w]ho may impeach" a witness and

Tarner v. State

938 So. 2d 635, 2006 Fla. App. LEXIS 16626, 2006 WL 2844225

District Court of Appeal of Florida | Filed: Oct 6, 2006 | Docket: 64847080

Cited 1 times | Published

wrong reason. As the state correctly notes, section 90.608(5), Florida Statutes, provides that a party

Izquierdo v. State

890 So. 2d 1263, 2005 WL 119552

District Court of Appeal of Florida | Filed: Jan 21, 2005 | Docket: 1690388

Cited 1 times | Published

to prove the truth of the matters asserted. See § 90.608, Fla. Stat. (2004). Second, Appellant argues that

Mouery v. State

884 So. 2d 1029, 2004 WL 2290405

District Court of Appeal of Florida | Filed: Oct 13, 2004 | Docket: 1683186

Cited 1 times | Published

this evidence should have been admitted under section 90.608(2), Florida Statutes (2002), which provides

State v. Robinson

711 So. 2d 619, 1998 Fla. App. LEXIS 5704, 1998 WL 256688

District Court of Appeal of Florida | Filed: May 22, 1998 | Docket: 64781148

Cited 1 times | Published

admissible on retrial as impeachment evidence under section 90.608, Florida Statutes (1997). However, the very

Nelson v. State

704 So. 2d 752, 1998 WL 31822

District Court of Appeal of Florida | Filed: Jan 30, 1998 | Docket: 1354181

Cited 1 times | Published

elicit testimony showing the bias of a witness. See § 90.608(2), Fla. Stat. (1995); Breedlove v. State, 580

Sheffield v. State

580 So. 2d 790, 1991 WL 65353

District Court of Appeal of Florida | Filed: Jun 26, 1991 | Docket: 2529201

Cited 1 times | Published

of impeaching the defendant at trial. Also, section 90.608(1)(a), Florida Statutes (1989), which allows

Pate v. State

529 So. 2d 328, 1988 WL 77950

District Court of Appeal of Florida | Filed: Jul 29, 1988 | Docket: 1523769

Cited 1 times | Published

v. State, 104 So.2d 77 (Fla. 2d DCA 1958). Section 90.608, Florida Statutes (1985) permits the impeachment

Strickland v. State

498 So. 2d 1350, 11 Fla. L. Weekly 2622, 1986 Fla. App. LEXIS 11364

District Court of Appeal of Florida | Filed: Dec 15, 1986 | Docket: 64623750

Cited 1 times | Published

defendant, is governed by the provisions of Section 90.608(l)(b), Florida Statutes, which allows, among

Parnell v. State

500 So. 2d 558, 11 Fla. L. Weekly 2273

District Court of Appeal of Florida | Filed: Oct 29, 1986 | Docket: 1295281

Cited 1 times | Published

State, 452 So.2d 559 (Fla. 1984). However, Section 90.608(2), Florida Statutes (1983) provides that a

Ernest D. Suggs v. State of Florida

Supreme Court of Florida | Filed: Sep 4, 2025 | Docket: 71267629

Published

Taylor and Byars lied at trial. 10. Section 90.608, Florida Statutes, sets forth certain types

Anthawn Regan, Jr. v. the State of Florida

District Court of Appeal of Florida | Filed: Aug 27, 2025 | Docket: 71210000

Published

impeach him with prior inconsistent statements. See § 90.608(1), Fla. Stat.; Morton v. State, 689 So. 2d 259

McCray v. State of Florida

District Court of Appeal of Florida | Filed: Aug 13, 2025 | Docket: 71098305

Published

Impeachment statute Section 90.608, Florida Statutes, governs the impeachment

Atoya Holmes v. the State of Florida

District Court of Appeal of Florida | Filed: Jun 11, 2025 | Docket: 70513843

Published

facts, see § 90.404(1)(c) (character of witness), § 90.608(5) (contradiction on relevant facts).”).

Shannon Gallagher v. State of Florida

District Court of Appeal of Florida | Filed: Jun 11, 2025 | Docket: 70513852

Published

any testimony they may provide against her. See § 90.608, Fla. Stat. (2025) (“Any party, including the

Latrice Pla v. Ashley Rierson

District Court of Appeal of Florida | Filed: Mar 19, 2025 | Docket: 69760062

Published

inconsistent with the witness’s present testimony.” § 90.608, Fla. Stat. “The admission or rejection of impeaching

Brianne Middlebrook v. State of Florida

District Court of Appeal of Florida | Filed: Mar 7, 2025 | Docket: 69714793

Published

bias or motive of a witness.”). Specifically, Section 90.608(2), Florida Statutes (2022), provides that

Latrice Pla v. Ashley Rierson

District Court of Appeal of Florida | Filed: May 15, 2024 | Docket: 68465996

Published

inconsistent with the witness’s present testimony.” § 90.608(1), Fla. Stat. “The admission or rejection of

ANDREW JAMES LYDECKER v. STATE OF FLORIDA

District Court of Appeal of Florida | Filed: Apr 5, 2024 | Docket: 68411312

Published

relevance." Thorne, 271 So. 3d at 184. Under section 90.608(2), Florida Statutes (2019), a party can attack

Marlin L. Joseph v. State of Florida

Supreme Court of Florida | Filed: Feb 10, 2022 | Docket: 62989167

Published

was being disrespectful. Pursuant to section 90.608, Florida Statutes (2017), “[a]ny party, including

Jason Andrew Simpson v. State of Florida & Jason Andrew Simpson v. Ricky D. Dixon, etc.

Supreme Court of Florida | Filed: Jan 13, 2022 | Docket: 62555121

Published

attacked by showing that the witness is biased. § 90.608(1)(b), Fla. Stat. (1981). A witness’ relationship

Brent A. Dodgen v. Kaitlyn P. Grijalva

Supreme Court of Florida | Filed: Oct 21, 2021 | Docket: 60663531

Published

witness’s credibility based on bias,” id. (citing § 90.608(2), Fla. Stat. (2015)), the credibility of the

Steven Younkin v. Nathan Blackwelder

Supreme Court of Florida | Filed: Oct 14, 2021 | Docket: 60646064

Published

the doctor’s credibility based on bias. See § 90.608(2), Fla. Stat. (2016). Nevertheless, this appears

Brent A. Dodgen v. Kaitlyn P. Grijalva

Supreme Court of Florida | Filed: Oct 14, 2021 | Docket: 60646077

Published

witness’s credibility based on bias,” id. (citing § 90.608(2), Fla. Stat. (2015)), the credibility of the

Dontae R. Morris v. State of Florida

Supreme Court of Florida | Filed: Apr 8, 2021 | Docket: 59804372

Published

90.801, Fla. Stat. (2020) (defining hearsay); § 90.608, Fla. Stat. (2020) (providing for impeachment

DONALD LAMORE v. STATE OF FLORIDA

District Court of Appeal of Florida | Filed: Sep 4, 2020 | Docket: 18411941

Published

when offered for impeachment purposes); see also § 90.608(2), Fla. Stat. (2009) ("Any party . . .

Tina Lasonya Brown v. State of Florida & Tina Lasonya Brown v. Mark S. Inch, etc.

Supreme Court of Florida | Filed: Aug 27, 2020 | Docket: 17505087

Published

to impeach Lee through evidence of bias. See § 90.608(2). Specifically, Brown argues Lee’s husband,

JUSTIN J. HAWN v. STATE OF FLORIDA

District Court of Appeal of Florida | Filed: Jul 22, 2020 | Docket: 17370648

Published

2d 561, 569 (Fla. 2004) (citations omitted). Section 90.608(1), Florida Statutes (2018), allows a party

JAMES GENTRY v. STATE OF FLORIDA

District Court of Appeal of Florida | Filed: Jul 22, 2020 | Docket: 17370651

Published

as prior inconsistent statements pursuant to section 90.608(1), Florida Statutes (2019). Second, based

Travis R. Brown v. State of Florida

District Court of Appeal of Florida | Filed: Aug 22, 2019 | Docket: 16095932

Published

inconsistent with Perry’s trial testimony. See § 90.608, Fla. Stat. (“Any party . . . may attack the

Rivera v. State

274 So. 3d 537

District Court of Appeal of Florida | Filed: Jun 21, 2019 | Docket: 64718357

Published

attack a witness's credibility based on bias. § 90.608(2), Fla. Stat. (2014) ("Any party, including the

George v. State

251 So. 3d 262

District Court of Appeal of Florida | Filed: Jul 5, 2018 | Docket: 7361265

Published

completely unrelated to the defendant’s case. Section 90.608, Florida Statutes (2016), provides that “[a]ny

Byrd v. State

221 So. 3d 659, 2017 WL 2569782, 2017 Fla. App. LEXIS 8668

District Court of Appeal of Florida | Filed: Jun 14, 2017 | Docket: 60268327

Published

witness being impeached. § 90.608, Fla. Stat. (2014). Our reading of section 90.608 leads us to conclude

Heather Worley v. Central Florida Young Men's Christian, etc.

228 So. 3d 18, 2017 WL 1366126

Supreme Court of Florida | Filed: Apr 13, 2017 | Docket: 4684625

Published

truthfulness of the witness’s testimony.” Id. And section 90.608, Florida Statutes, provides that “[a]ny party

J.G. v. State

213 So. 3d 936, 2017 WL 1014495, 2017 Fla. App. LEXIS 3434

District Court of Appeal of Florida | Filed: Mar 15, 2017 | Docket: 60263952

Published

as to the form of the statements permitted. See § 90.608(1), Fla. Stat. (2015). We have previously discussed

Musson v. State

184 So. 3d 575, 2016 Fla. App. LEXIS 828, 2016 WL 275271

District Court of Appeal of Florida | Filed: Jan 22, 2016 | Docket: 3030238

Published

Curtis’ credibility as a witness. See § 90.608(2), Fla. Stat. (2013) (“Any party ... may attack

Raul Eduardo Banegas-Membran v. State of Florida

182 So. 3d 865, 2016 Fla. App. LEXIS 235, 2016 WL 72547

District Court of Appeal of Florida | Filed: Jan 6, 2016 | Docket: 3026026

Published

97 So.3d 301, 304 (Fla. 4th DCA 2012). “Section 90.608(2), Florida Statutes, permits cross-examination

Kareem Daniel Farrell v. State of Florida

186 So. 3d 1046, 2015 Fla. App. LEXIS 7069, 2015 WL 2214148

District Court of Appeal of Florida | Filed: May 13, 2015 | Docket: 2679347

Published

questions were nonetheless improper. Under section 90.608, Florida Statutes (2013), parties can impeach

Lloyd Phelps v. State of Florida

154 So. 3d 1232

District Court of Appeal of Florida | Filed: Jan 29, 2015 | Docket: 2629729

Published

1 in light of the 1990 amendment to section 90.608, Florida Statutes, which allows for any party

Lennart S. Koo v. State of Florida

149 So. 3d 693

District Court of Appeal of Florida | Filed: Sep 1, 2014 | Docket: 1132060

Published

the credibility of the victim’s testimony. See § 90.608(1), Fla. Stat. (2012) (a witness may be impeached

Neil Brown v. Esther Mittelman

152 So. 3d 602, 2014 Fla. App. LEXIS 13403, 2014 WL 4209207

District Court of Appeal of Florida | Filed: Aug 27, 2014 | Docket: 1145912

Published

credibility of a witness by exposing a potential bias. § 90.608(2), Fla. Stat. (2009). The financial relationship

Darious Wilcox v. State of Florida

Supreme Court of Florida | Filed: Jul 10, 2014 | Docket: 400988

Published

a prior inconsistent statement pursuant to section 90.608, Florida Statutes (2008), the prior statement

Martinez v. State

125 So. 3d 985, 2013 WL 3197139, 2013 Fla. App. LEXIS 10069

District Court of Appeal of Florida | Filed: Jun 26, 2013 | Docket: 60236152

Published

proper as an effort to uncover potential bias. See § 90.608(2), Fla. Stat. (2011). However, in the question

Harrell v. State

108 So. 3d 1146, 2013 WL 1007283, 2013 Fla. App. LEXIS 4197

District Court of Appeal of Florida | Filed: Mar 15, 2013 | Docket: 60228995

Published

non-hearsay and admissible to show bias under section 90.608(2), Florida Statutes. See, e.g., Kearney v

Louis v. State

104 So. 3d 1126, 2012 WL 5870078, 2012 Fla. App. LEXIS 20225

District Court of Appeal of Florida | Filed: Nov 21, 2012 | Docket: 60227296

Published

to attack the credibility of a witness.” Id. Section 90.608(1), Florida Statutes (2008), allows for the

State v. Jouzdani

98 So. 3d 1264, 2012 WL 5076096

District Court of Appeal of Florida | Filed: Oct 19, 2012 | Docket: 60312168

Published

v. State, 48 So.3d 843 (Fla. 1st DCA 2010). Section 90.608, Florida Statutes, (2008), lists the grounds

Rodriguez v. State

65 So. 3d 1133, 2011 Fla. App. LEXIS 11007, 2011 WL 2694428

District Court of Appeal of Florida | Filed: Jul 13, 2011 | Docket: 60301630

Published

admissible as a prior inconsistent statement under section 90.608(1), Florida Statutes (2008). If the earlier

BM v. State

66 So. 3d 1013, 2011 WL 3307520

District Court of Appeal of Florida | Filed: Jul 6, 2011 | Docket: 2361418

Published

to show the bias of prosecution witnesses. See § 90.608(2), Fla. Stat. (1993); see also Diaz v. State

State v. Smith

52 So. 3d 821, 2011 Fla. App. LEXIS 240, 2011 WL 180364

District Court of Appeal of Florida | Filed: Jan 21, 2011 | Docket: 2406328

Published

identification testimony of Lee Keith and Tommy Whitmer. § 90.608, Fla. Stat. (2008). If the trier of fact was to

Special v. Baux

52 So. 3d 682, 2010 Fla. App. LEXIS 9114, 2010 WL 2523942

District Court of Appeal of Florida | Filed: Jun 23, 2010 | Docket: 60297836

Published

651 So.2d 713, 715 (Fla. 2d DCA 1995)). See also § 90.608(5), Fla. Stat. (2003) (providing that any party

Childers v. Floyd

608 F.3d 776, 2010 U.S. App. LEXIS 11605, 2010 WL 2274481

Court of Appeals for the Eleventh Circuit | Filed: Jun 8, 2010 | Docket: 65659192

Published

Constitution, Fla. Const, art I, § 16, Fla. Stat. § 90.608, and Florida case law.7 The denial occurred when

Jeancharles v. State

25 So. 3d 656, 2010 Fla. App. LEXIS 30, 2010 WL 22703

District Court of Appeal of Florida | Filed: Jan 6, 2010 | Docket: 60287644

Published

testified to by the witness being impeached.” § 90.608(5), Fla. Stat. (2009) (emphasis added). “An issue

State Farm Mutual Automobile Insurance v. German

12 So. 3d 1286, 2009 Fla. App. LEXIS 10070

District Court of Appeal of Florida | Filed: Jul 24, 2009 | Docket: 60233773

Published

bias he or she might have for or against a party. § 90.608(2), Fla. Stat. (2009). For example, a treating

STATE FARM MUT. AUTO. INS. CO. v. German

12 So. 3d 1286, 2009 WL 2190218

District Court of Appeal of Florida | Filed: Jul 24, 2009 | Docket: 1145592

Published

bias he or she might have for or against a party. § 90.608(2), Fla. Stat. (2009). For example, a treating

GAEDTKE v. McNeil

612 F. Supp. 2d 1209, 2009 U.S. Dist. LEXIS 29093, 2009 WL 800135

District Court, M.D. Florida | Filed: Mar 25, 2009 | Docket: 2361666

Published

statements to law enforcement. See Fla. Evid.Code § 90.608(1).[18] Thus, to summarize, the State's evidence

State v. Patterson

966 So. 2d 471, 2007 WL 2963680

District Court of Appeal of Florida | Filed: Oct 12, 2007 | Docket: 1679425

Published

would naturally have been mentioned." (citing § 90.608(1), Fla. Stat. (1995), and State v. Smith, 573

Felton v. State

949 So. 2d 342, 2007 WL 601604

District Court of Appeal of Florida | Filed: Feb 28, 2007 | Docket: 1719884

Published

the matters about which the witness testified." § 90.608(4), Fla. Stat. (2006). A witness's drug use at

Graves v. State

937 So. 2d 1286, 2006 Fla. App. LEXIS 16437, 2006 WL 2818813

District Court of Appeal of Florida | Filed: Oct 4, 2006 | Docket: 64846909

Published

witness by showing that the witness is biased. § 90.608(2), Fla. Stat. (2005). A defendant in a criminal

Pietri v. State

935 So. 2d 85, 2006 Fla. App. LEXIS 13011, 2006 WL 2190750

District Court of Appeal of Florida | Filed: Aug 4, 2006 | Docket: 64845946

Published

under the facts of this case as impeachment. See § 90.608, Fla. Stat. (2005). To the extent that the testimony

Childers v. State

931 So. 2d 86, 2006 Fla. App. LEXIS 17207, 2006 WL 237081

District Court of Appeal of Florida | Filed: Feb 2, 2006 | Docket: 64845369

Published

him to testify falsely against Mr. Childers. See § 90.608(2), Fla. Stat. (2002) (“Any party ... may attack

C.L.W. v. State

920 So. 2d 109, 2006 Fla. App. LEXIS 435, 2006 WL 141466

District Court of Appeal of Florida | Filed: Jan 20, 2006 | Docket: 64842137

Published

preclude admission of the statements at issue. See § 90.608, Fla. Stat. (2005) (providing that “[a]ny party

Sorge v. State

915 So. 2d 707, 2005 Fla. App. LEXIS 18689, 2005 WL 3159587

District Court of Appeal of Florida | Filed: Nov 29, 2005 | Docket: 64841066

Published

State, 591 So.2d 922 (Fla.1991); see also section 90.608(2), Florida Statutes. Although decisions such

Eaton Corp. v. Votour

895 So. 2d 466, 2005 Fla. App. LEXIS 1229, 2005 WL 277910

District Court of Appeal of Florida | Filed: Feb 7, 2005 | Docket: 64836437

Published

appropriately considered as impeaching evidence. Section 90.608(5), Florida Statutes, authorizes the impeachment

Nova v. State

874 So. 2d 1263, 2004 Fla. App. LEXIS 8310, 2004 WL 1283778

District Court of Appeal of Florida | Filed: Jun 11, 2004 | Docket: 64831032

Published

showing that she was biased in accordance with section 90.608(2), Florida Statutes (2003), which reads succinctly:

Daeda v. State

841 So. 2d 632, 2003 Fla. App. LEXIS 4486, 2003 WL 1786085

District Court of Appeal of Florida | Filed: Apr 4, 2003 | Docket: 64821782

Published

that are inconsistent with her present testimony. § 90.608(1), Fla. Stat. (1997). As we recognized in Williams

Henry v. State

825 So. 2d 431, 2002 WL 1378625

District Court of Appeal of Florida | Filed: Jun 27, 2002 | Docket: 2552785

Published

attacking the credibility of a witness, see section 90.608(2), Florida Statutes (1999), and the Florida

Owens v. State

817 So. 2d 1006, 2002 Fla. App. LEXIS 7621, 2002 WL 1070098

District Court of Appeal of Florida | Filed: May 31, 2002 | Docket: 64815520

Published

not inconsistent with his trial testimony. Section 90.608(l)(a), Florida Statutes, allows any party,

Martin v. State

797 So. 2d 6, 2001 Fla. App. LEXIS 7523, 2001 WL 527520

District Court of Appeal of Florida | Filed: May 16, 2001 | Docket: 64809412

Published

showing that the witness is *8biased. See Fla. Stat. § 90.608 (1999). “Florida courts have recognized that a

Sorondo v. Batet

782 So. 2d 540, 2001 Fla. App. LEXIS 5174, 2001 WL 387512

District Court of Appeal of Florida | Filed: Apr 18, 2001 | Docket: 64804783

Published

“impeachment” of the doctor’s direct testimony under section 90.608, Florida Statutes (1999), is correct, it was

Laur v. State

781 So. 2d 452, 2001 Fla. App. LEXIS 2459, 2001 WL 219230

District Court of Appeal of Florida | Filed: Mar 7, 2001 | Docket: 64804510

Published

witness with a prior inconsistent statement. Section 90.608(1), Florida Statutes (2000), permits any party

Wiggins v. State

773 So. 2d 1259, 2000 Fla. App. LEXIS 16624, 2000 WL 1854105

District Court of Appeal of Florida | Filed: Dec 20, 2000 | Docket: 64802596

Published

statement was admitted for impeachment purposes. See § 90.608(1), Fla.Stat. (1999); Ellis v. State, 622 So.2d

Roper v. State

763 So. 2d 487, 2000 Fla. App. LEXIS 8764, 2000 WL 959759

District Court of Appeal of Florida | Filed: Jul 12, 2000 | Docket: 64799022

Published

section 90.610. The state asserts that under section 90.608, Florida Statutes (1997), it can attack the

Jones v. State

765 So. 2d 767, 2000 Fla. App. LEXIS 8026, 2000 WL 826954

District Court of Appeal of Florida | Filed: Jun 28, 2000 | Docket: 64799861

Published

plea agreement or other deal with the state, see § 90.608(2), Fla. Stat. (1997), Livingston v. State, 678

Egberongbe v. State

765 So. 2d 108, 2000 Fla. App. LEXIS 6803, 2000 WL 718160

District Court of Appeal of Florida | Filed: Jun 6, 2000 | Docket: 64799671

Published

witness’s testimony under the rules of evidence. See § 90.608, Fla. Stat. (1993); D.J.G., 524 So.2d at 1027

Wilson v. State

743 So. 2d 1222, 1999 Fla. App. LEXIS 15141, 1999 WL 1036565

District Court of Appeal of Florida | Filed: Nov 17, 1999 | Docket: 64791956

Published

admissible for impeachment purposes pursuant to section 90.608(5), Florida Statutes. In response to an order

Breedlove v. Moore

74 F. Supp. 2d 1226, 1999 U.S. Dist. LEXIS 17808, 1999 WL 1049619

District Court, S.D. Florida | Filed: Sep 8, 1999 | Docket: 2296831

Published

the evidence would be admissible under Fla.Stat. § 90.608 as evidence of bias in this case, where no criminal

Washington v. State

737 So. 2d 1208, 1999 Fla. App. LEXIS 10059

District Court of Appeal of Florida | Filed: Jul 27, 1999 | Docket: 64789652

Published

as testified to by the witness being impeached. § 90.608, Fla. Stat. (1997). This provision is a proper

Simmons v. State

722 So. 2d 862, 1998 Fla. App. LEXIS 14778, 1998 WL 821761

District Court of Appeal of Florida | Filed: Nov 20, 1998 | Docket: 64784982

Published

by the defendant on his direct questioning. Section 90.608, Florida Statutes, has been amended since Gelabert

Davis v. State

717 So. 2d 61, 1998 Fla. App. LEXIS 5981, 1998 WL 279209

District Court of Appeal of Florida | Filed: May 29, 1998 | Docket: 64782603

Published

the landowners to testify. We do not agree. Section 90.608 allows impeachment by “proof of other witnesses

C.M. v. State

698 So. 2d 1306, 1997 Fla. App. LEXIS 9694

District Court of Appeal of Florida | Filed: Aug 27, 1997 | Docket: 64775619

Published

Oil Co., 589 So.2d 373 (Fla. 4th DCÁ 1991). Section 90.608(5), Florida Statutes (1995), allows impeachment

Perez v. State

691 So. 2d 1190, 1997 Fla. App. LEXIS 4187, 1997 WL 194470

District Court of Appeal of Florida | Filed: Apr 23, 1997 | Docket: 64772557

Published

Mary Colon. Such evidence was admissible under section 90.608(l)(b), Florida Statutes (1995), as evidence

Williams v. State

689 So. 2d 393, 1997 Fla. App. LEXIS 1838

District Court of Appeal of Florida | Filed: Mar 5, 1997 | Docket: 64771644

Published

observation of the entire traumatic event. See § 90.608(4), Fla. Stat. (1995). Accordingly, we hold that

Arrocha v. State

687 So. 2d 57, 1997 Fla. App. LEXIS 268, 1997 WL 30934

District Court of Appeal of Florida | Filed: Jan 29, 1997 | Docket: 64770628

Published

PER CURIAM. Affirmed. See § 90.608, Fla. Stat. (1993); Alexander v. State, 627 So.2d 35 (Fla. 1st DCA

Adventist Health System/Sunbelt, Inc. v. Watkins

675 So. 2d 1051, 1996 Fla. App. LEXIS 7034, 1996 WL 368747

District Court of Appeal of Florida | Filed: Jul 5, 1996 | Docket: 64765554

Published

medical records, then it must not have happened. See § 90.608, Fla. Stat. (1995). Moreover, section 90.614,

Howell v. State

667 So. 2d 869, 1996 Fla. App. LEXIS 544, 1996 WL 34059

District Court of Appeal of Florida | Filed: Jan 31, 1996 | Docket: 64762196

Published

v. State, 139 Fla. 542, 190 So. 691 (1939). Section 90.608(l)(a), Florida Statutes. See also Williams

Banks v. State

648 So. 2d 766, 1994 WL 646260

District Court of Appeal of Florida | Filed: Nov 18, 1994 | Docket: 64753429

Published

matters about which the witness had testified. § 90.608(4), Fla. Stat. (1991). It would appear, therefore

Luttrell v. Roger Holler Chevrolet

625 So. 2d 921, 1993 WL 408225

District Court of Appeal of Florida | Filed: Oct 15, 1993 | Docket: 1517600

Published

himself signed were properly admissible under Section 90.608(1)(a), Florida Statutes (1989), which allows

Pottgen v. State

616 So. 2d 1125, 1993 Fla. App. LEXIS 4419, 1993 WL 107062

District Court of Appeal of Florida | Filed: Apr 13, 1993 | Docket: 64695654

Published

his prior inconsistent statements pursuant to section 90.608(2), Florida Statutes (1989). While the appellant’s

Cantero v. State

612 So. 2d 634, 1993 Fla. App. LEXIS 86, 1993 WL 5348

District Court of Appeal of Florida | Filed: Jan 13, 1993 | Docket: 64693745

Published

argues that the impeachment was proper under section 90.608(l)(e), Florida Statutes (1989), which allows

Pawlendzio v. Senco Products, Inc.

610 So. 2d 734, 1992 Fla. App. LEXIS 13126, 1992 WL 389044

District Court of Appeal of Florida | Filed: Dec 31, 1992 | Docket: 64692871

Published

through section 90.102, Florida Statutes (1987), section 90.608, Florida Statutes (1987), supersedes section

Parsons v. State

608 So. 2d 67, 1992 Fla. App. LEXIS 10698, 1992 WL 282064

District Court of Appeal of Florida | Filed: Oct 16, 1992 | Docket: 64691772

Published

the statements she made in this trial, under section 90.608, Florida Statutes (Supp.1990).

Recio v. State

605 So. 2d 553, 1992 WL 235261

District Court of Appeal of Florida | Filed: Sep 22, 1992 | Docket: 1343533

Published

(same), cert. denied, 303 So.2d 26 (Fla. 1974); § 90.608(4), Fla. Stat. (1991) (credibility of witness

Brockington v. State

600 So. 2d 29, 1992 Fla. App. LEXIS 6023, 1992 WL 119838

District Court of Appeal of Florida | Filed: Jun 3, 1992 | Docket: 64667887

Published

but refused to grant a mistrial. Although section 90.608(1), Florida Statutes (1991), allows impeachment

Cruz v. State

593 So. 2d 312, 1992 Fla. App. LEXIS 760, 1992 WL 16582

District Court of Appeal of Florida | Filed: Feb 4, 1992 | Docket: 64665137

Published

3d DCA), rev. denied, 424 So.2d 763 (Fla.1982); § 90.608(1H2), Fla.Stat. (1989). Moreover, the trial court

Williams v. State

582 So. 2d 89, 1991 Fla. App. LEXIS 5876, 1991 WL 110850

District Court of Appeal of Florida | Filed: Jun 26, 1991 | Docket: 64659985

Published

deposition was admissible under the provisions of section 90.608, Florida Statutes (1987), for impeachment purposes

Williams v. State

582 So. 2d 89, 1991 Fla. App. LEXIS 5876, 1991 WL 110850

District Court of Appeal of Florida | Filed: Jun 26, 1991 | Docket: 64659985

Published

deposition was admissible under the provisions of section 90.608, Florida Statutes (1987), for impeachment purposes

J.S. v. State

588 So. 2d 593, 1991 Fla. App. LEXIS 4116

District Court of Appeal of Florida | Filed: May 7, 1991 | Docket: 64662773

Published

§ 39.11(l)(f), Fla.Stat. (1987). Affirmed. . § 90.608, Fla.Stat. (1987) (since modified Ch. 90-174,

McCoy v. State

580 So. 2d 181, 1991 Fla. App. LEXIS 2723, 1991 WL 77619

District Court of Appeal of Florida | Filed: Mar 29, 1991 | Docket: 64658973

Published

allowed where the witness has proven to be adverse. § 90.608(2), Fla.Stat. (1989); Austin v. State, 461 So

Bada v. State

573 So. 2d 454, 1991 Fla. App. LEXIS 1021, 1991 WL 15597

District Court of Appeal of Florida | Filed: Feb 12, 1991 | Docket: 64655970

Published

Kimble v. State, 537 So.2d 1094 (Fla. 2d DCA 1989); § 90.608(1)(a), Fla.Stat. (1987). Accordingly, the defendant’s

Wolcoff v. State

576 So. 2d 726, 1991 Fla. App. LEXIS 16, 1991 WL 132

District Court of Appeal of Florida | Filed: Jan 4, 1991 | Docket: 64657418

Published

its own witness when the witness proved adverse. § 90.608(2), Fla. Stat. (1987).1 However, those rules were

Miles v. Allstate Insurance Co.

564 So. 2d 583, 1990 Fla. App. LEXIS 5350, 1990 WL 102714

District Court of Appeal of Florida | Filed: Jul 25, 1990 | Docket: 64651874

Published

doctor’s credibility within the purview of section 90.608, Florida Statutes (1989). It more nearly approaches

Annis v. First Union National Bank of Florida

566 So. 2d 273, 1990 Fla. App. LEXIS 4879, 1990 WL 95336

District Court of Appeal of Florida | Filed: Jul 6, 1990 | Docket: 64652701

Published

most common form of impeachment evidence. See Section 90.608(l)(a), Florida Statutes (1989). Appellees’

Henriquez v. State

553 So. 2d 716, 14 Fla. L. Weekly 2827, 1989 Fla. App. LEXIS 6851, 1989 WL 147942

District Court of Appeal of Florida | Filed: Dec 6, 1989 | Docket: 64646940

Published

expressly for impeachment purposes pursuant to section 90.608(l)(a), Florida Statutes (1987) (prior statements

McCrae v. State

549 So. 2d 1122, 14 Fla. L. Weekly 2394, 1989 Fla. App. LEXIS 5664, 1989 WL 118915

District Court of Appeal of Florida | Filed: Oct 10, 1989 | Docket: 64645368

Published

attacked by showing that the witness is biased, Section 90.608(l)(b), Florida Statutes (1987), appellant’s

Rotte v. City of Jacksonville

543 So. 2d 842, 14 Fla. L. Weekly 1192, 1989 Fla. App. LEXIS 2705, 1989 WL 49602

District Court of Appeal of Florida | Filed: May 16, 1989 | Docket: 64642715

Published

Statutes (1981), read in pari materia with section 90.608(2) and Florida Rule of Civil Procedure 1.450(a)

Quinones v. State

528 So. 2d 46, 13 Fla. L. Weekly 1523, 1988 Fla. App. LEXIS 2889, 1988 WL 65190

District Court of Appeal of Florida | Filed: Jun 28, 1988 | Docket: 64635872

Published

punish-ment_ (Emphasis supplied.) Similarly, section 90.608(1)(a), Florida Statutes (1985),2 provides no

O'Reilly v. State

516 So. 2d 106, 12 Fla. L. Weekly 2781, 1987 Fla. App. LEXIS 11468, 1987 WL 2280

District Court of Appeal of Florida | Filed: Dec 9, 1987 | Docket: 64631241

Published

counsel have been permitted to do so pursuant to section 90.608, Florida Statutes (1985), but refusal to allow

D.J.G. v. State

524 So. 2d 1024, 12 Fla. L. Weekly 2806, 1987 Fla. App. LEXIS 11583

District Court of Appeal of Florida | Filed: Dec 9, 1987 | Docket: 64634704

Published

witness has been retained at § 90.608(1), Fla.Stat. (1985). The portions of § 90.608 relevant to this case state:

Kirkland v. State

495 So. 2d 831, 11 Fla. L. Weekly 2118, 1986 Fla. App. LEXIS 9986

District Court of Appeal of Florida | Filed: Oct 6, 1986 | Docket: 64622206

Published

was declared an adverse witness pursuant to Section 90.608(2), Florida Statutes. Subsequently, over defense

Lawhorne v. State

481 So. 2d 19, 10 Fla. L. Weekly 2672, 1985 Fla. App. LEXIS 17135

District Court of Appeal of Florida | Filed: Dec 3, 1985 | Docket: 64616553

Published

attacking the credibility of its own witness. See § 90.608(l)(c), Fla.Stat. (1983). This court, in dicta

State v. Barber

465 So. 2d 624, 10 Fla. L. Weekly 781, 1985 Fla. App. LEXIS 13059

District Court of Appeal of Florida | Filed: Mar 20, 1985 | Docket: 64610707

Published

credible before he even testified at the trial. Section 90.608, Florida Statutes (1983), dealing with impeachment

Tallahassee Junior Academy v. Unemployment Appeals Commission

461 So. 2d 968, 9 Fla. L. Weekly 2576, 1984 Fla. App. LEXIS 16686

District Court of Appeal of Florida | Filed: Dec 11, 1984 | Docket: 64609152

Published

testified to by the witness being impeached.” Section 90.608(l)(e). No doubt the major difficulty appellant

Tallahassee Junior Academy v. Unemployment Appeals Commission

461 So. 2d 968, 9 Fla. L. Weekly 2576, 1984 Fla. App. LEXIS 16686

District Court of Appeal of Florida | Filed: Dec 11, 1984 | Docket: 64609152

Published

testified to by the witness being impeached.” Section 90.608(l)(e). No doubt the major difficulty appellant

Hamilton v. State

433 So. 2d 1027, 1983 Fla. App. LEXIS 20226

District Court of Appeal of Florida | Filed: Jun 30, 1983 | Docket: 64597993

Published

Brown v. State, 428 So.2d 250 (Fla.1983); Section 90.-608(1)(e), Florida Statutes (1981); and Yesbick

Plasencia v. State

426 So. 2d 1051, 1983 Fla. App. LEXIS 18540

District Court of Appeal of Florida | Filed: Jan 25, 1983 | Docket: 64595099

Published

Plasencia did not testify at trial, thus neither section 90.608(l)(c), Florida Statutes (1981), nor section

Jones v. State

418 So. 2d 430, 1982 Fla. App. LEXIS 20991

District Court of Appeal of Florida | Filed: Aug 24, 1982 | Docket: 64591802

Published

for impeachment by prior inconsistent statement. § 90.608(1)(a), Fla. Stat. (1979); Henderson v. State,

Tipton v. State

402 So. 2d 479, 1981 Fla. App. LEXIS 20769

District Court of Appeal of Florida | Filed: Aug 4, 1981 | Docket: 64584649

Published

prosecutor and interrogated on direct examination, Section 90.608(2), Florida Statutes (1979), *480because she