The 2023 Florida Statutes (including Special Session C)
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. . . . § 92.54. . . .
. . . victim-Knight's daughter-to testify through a closed-circuit television system pursuant to section 92.54 . . . See § 92.54(5), Fla. Stat. . . . Consistent with that interest, sections 92.53 and 92.54, Florida Statutes, allow children to testify . . . State , 565 So.2d 315, 318 (Fla. 1990) ("[T]he factual findings required by section 92.54 are necessarily . . . have "the right to immediate and direct communication with counsel conducting cross-examination," § 92.54 . . .
. . . . § 92.54. . . .
. . . . § 92.54. . . .
. . . screen as opposed to having the child testify via closed circuit television as permitted by section 92.54 . . .
. . . Overholt argues that the court should have followed the procedure of section 92.54, Florida Statutes . . . Section 92.54 provides: (1) Upon motion and hearing in camera and upon a finding that there is a substantial . . .
. . . The State moved, pursuant to section 92.54, Florida Statutes (2010), to place a projector screen between . . . We agreed with the Parker analysis and concluded “that section 92.54 does not authorize the use of a . . .
. . . an unimpaired class comprised of all holders of non-asbestos-related general unsecured claims, voted 92.54% . . .
. . . After the trial started, the State made a motion pursuant to section 92.54, Florida Statutes (2010), . . . State, 819 So.2d 815 (Fla. 1st DCA 2002), that “section 92.54 provides for the use of closed circuit . . . We conclude that section 92.54 does not authorize the use of a screen in the manner employed in this . . . See § 92.54, Fla. Stat. . . . the testimony of the child ... but shall ensure that the child ... cannot hear or see the defendant. 92.54 . . .
. . . . § 92.54, While letters rogatory may be utilized to "serve process on an individual or corporation within . . . the comity of courts toward each other, and customarily embody a promise of reciprocity." 22 C.F.R. § 92.54 . . .
. . . . § 92.54. . . .
. . . (c) The use of testimony taken outside of the courtroom, including proceedings under ss. 92.53 and 92.54 . . .
. . . See § 92.54, Fla. Stat. (2009). . . .
. . . In addition, the State, citing to section 92.54, Florida Statutes (2007), argued that the defendant’s . . . order allowing the defendant’s minor children to testify via satellite from Ecuador cites to section 92.54 . . . In the instant case, section 92.54 is inapplicable because the defendant’s motion does not allege that . . . Therefore, section 92.54 does not apply. . . . Although we conclude that section 92.54 does not apply in the instant case because the defendant does . . .
. . . Section 92.54, Florida Statutes, authorizes the court to allow a child to testify outside of the courtroom . . .
. . . So.2d 1372 (Fla.1994), Hopkins challenged both the sufficiency of the factual findings under section 92.54 . . . although the objection did not specifically address the sufficiency of the factual findings under section 92.54 . . . The court also held that “the factual findings required by section 92.54 are necessarily related to the . . . The Hopkins court first addressed the trial court’s lack of findings under section 92.54 and held that . . .
. . . Appellant that the trial court’s findings were insufficient to satisfy the requirements of section 92.54 . . . So.2d 1372, 1376 (Fla.l994)(holding that the trial court’s findings were insufficient under section 92.54 . . . Moreover, section 92.54 provides for the use of closed circuit television but not a partition. . . .
. . . The trial court denied the motion, finding that E.H. does not fall within the parameters of section 92.54 . . . Section 92.54(1), Fla. Stat. (2000). . . . the evidence presented satisfied the “at least moderate emotional or mental harm” element of section 92.54 . . . and was not mentally retarded, the court ruled that she was not entitled to the protection of section 92.54 . . . Section 92.54 does not provide the sole means by which a trial court may exercise its inherent authority . . .
. . . trial court erred as a matter of law in failing to make specific findings of fact mandated by section 92.54 . . . This is erroneous because it ignores the clear and unequivocal directive of section 92.54(5), requiring . . . because his objection did not specify that the trial court’s findings were insufficient under section 92.54 . . . properly preserves the issue of whether the trial court’s factual findings are sufficient under section 92.54 . . . WARNER, C.J., and GROSS, J., concur. . 92.54 Use of closed circuit television in proceedings involving . . .
. . . The state concedes the trial court failed to make the findings required by section 92.54(1), Florida . . . Upon retrial, the trial court should follow the requirements of section 92.54(1) before B.D. is permitted . . .
. . . Id. at 1376, quoting section 92.54(5), Florida Statutes. . . . Although Hopkins involved closed-circuit televising of trial testimony under section 92.54, Florida Statutes . . .
. . . Although the objection did not specifically address the sufficiency of the factual findings under section 92.54 . . .
. . . . § 92.54. . . .
. . . ); (4) rule 8.104 (testimony by closed-circuit television), to conform to 1993 revisions to section 92.54 . . .
. . . See § 92.54(5), Fla.Stat. (1991); Hopkins v. . . .
. . . So.2d 1372 (Fla.1994) (finding no fundamental error in failure to make findings required by section 92.54 . . .
. . . State, 632 So.2d 1372 (Fla.1994) (failure to make specific findings of fact under section 92.54, Florida . . .
. . . addressed the same question of fundamental error as it relates to the specific findings required by section 92.54 . . . Section 92.54, Florida Statutes (1989), permits a child under the age of sixteen who is a victim of or . . . Section 92.54 is almost identical to section 92.53 in requiring a finding “that there is a substantial . . . child will suffer at least moderate emotional or mental harm if required to testify in open court.” § 92.54 . . .
. . . importance: Does a trial court commit fundamental error by failing to make the findings required by section 92.54 . . . Pursuant to section 92.54, Florida Statutes (1989), the State filed a motion to present the trial testimony . . . Section 92.54(5), Fla.Stat. (1989). . . . Craig and those required by section 92.54); see also Feller v. . . . Section 92.54(5). . . .
. . . a child who witnessed a murder to present her testimony by videotape, relying on sections 92.53 and 92.54 . . .
. . . been a hearing held or specific findings of fact made on the state’s motion filed pursuant to section 92.54 . . .
. . . permitting the child victim to testify by closed-circuit television, which is authorized under Section 92.54 . . . appellant did not object to the trial court’s failure to make the specific findings required by section 92.54 . . . importance: DOES A TRIAL COURT COMMIT FUNDAMENTAL ERROR BY FAILING TO MAKE THE FINDINGS REQUIRED BY SECTION 92.54 . . .
. . . The district court found that sections 92.53 and 92.54, Florida Statutes (1989), did not allow the trial . . . We agree with the district court that sections 92.53 and 92.54 do not apply to the instant case because . . . testimony by way of videotape or closed-circuit television, except in the context of sections 92.53 and 92.54 . . .
. . . trial court’s decision to permit the child victim to testify by closed-circuit television under section 92.54 . . . So.2d 166 (Fla.1991) (even if the trial court failed to make specific findings required by section 92.54 . . . make findings required under sections 92.53 (permitting videotaped testimony of a child victim) and 92.54 . . .
. . . . § 92.54(1) (1987) — the counsel- or answered in the affirmative. No other evidence was presented. . . . Fla.Stat. § 92.54(1) (1987). . . . Stat. § 92.54(3) (1987). . . . Clearly, section 92.54(4) affects the defendant’s confrontation rights. . . . Fla.Stat. § 92.54(3) (1987) (emphasis added). .See Fla.Stat. § 92.54(4) (1987), supra note 2. . . . .
. . . Pursuant to section 92.54, Florida Statutes (1991), the victim testified via closed circuit television . . . In section 92.54, Florida Statutes (1991), among others, Florida has expressed such an interest. . . .
. . . In my view, sections 92.53 and 92.54 specify special procedures that differ considerably from the ordinary . . . supreme court the question of whether the failure to make findings under a companion statute, section 92.54 . . .
. . . Defenders argue that the proposed rule is too broad because it goes beyond the language of section 92.54 . . . We find that the rule should track the language of section 92.54, thus we delete the inclusion of “child . . . Finally, the Public Defenders point out that rule 8.104(a)(2) does track the language of section 92.54 . . . However, they argue that subsection 8.104(a)(2), like section 92.54, has the strange effect of allowing . . . While the revised rule 8.104 tracks the language of section 92.54, it is different from the statute because . . .
. . . contended that the child could testify by closed circuit television pursuant to the procedure of section 92.54 . . .
. . . Section 92.54, Florida Statutes (1989), permits a trial judge to order that the testimony of a child . . . Section 92.54(5) requires the judge to detail the reasons for his ruling with these words: “The court . . . Pursuant to section 92.54, the prosecutor sought to present the trial testimony of the alleged child . . . Section 92.53 sanctions such a procedure, but, as in section 92.54(5) at issue here, the trial court . . . We also recognize that section 92.54 authorizes a procedure which impacts an accused’s constitutional . . . admissibility of the child witness’s hearsay statements and the necessary findings required by section 92.54 . . . findings of fact after they are stated on the record by the court as required by sections 90.803(23) and 92.54 . . . findings of fact sufficient to admit otherwise inadmissible testimony under sections 90.803(23) and 92.54 . . . The statutory requirement in sections 90.803(23) and 92.54 that the basis of the court’s ruling be set . . .
. . . This last ruling was made pursuant to section 92.54(4), Florida Statutes (1987), which provides: During . . . of at least moderate emotional or mental harm if the child is required to testify in open court, § 92.54 . . .
. . . The legislature restricted the procedures contained in sections 92.53 and 92.54, Florida Statutes (1989 . . . As opposed to sections 92.53 and 92.54, where the legislature acted, section 92.55 is a nonoperative . . .
. . . The trial court neither violated the express language nor principles of Section 92.54(4), Florida Statutes . . .
. . . State, 568 So.2d 1014 (Fla. 3d DCA 1990) ((alleged violation of section 92.54(5), Florida Statutes (1989 . . .
. . . decide whether the trial court’s on-the-record findings contained the specificity required by section 92.54 . . .
. . . Section 92.54, Florida Statutes (1985), provides for the use of closed circuit television to obtain testimony . . .
. . . . § 92.54 (1989); Ga. Code Ann. § 17-8-55 (Supp. 1989); Ill. . . .
. . . at least moderate emotional or mental harm if required to testify in court,” as required by Section 92.54 . . .
. . . Justice O’Connor cited Section 92.54, Florida Statutes (1987), authorizing a child abuse witness to testify . . . an exception to the constitutional right of physical confrontation — namely, compliance with Section 92.54 . . . makes “specific findings of fact, on the record, as to the basis for its [above-stated] ruling,” § 92.54 . . . of fact on the record to support such a case-specific ruling — all of which are required by Section 92.54 . . . This being so, it is clear that Section 92.54, Florida Statutes (1987), was not complied with below, . . .
. . . the court permitted the use of a speaker only, not closed circuit television as required by Section 92.54 . . . testifying, and the defendant could communicate by any appropriate electronic method as required by Section 92.54 . . .
. . . trial or proceeding in which such witness testifies by use of closed circuit television pursuant to s. 92.54 . . .
. . . anteroom to the courtroom outside the presence of the defendant under the authority of sections 92.53 and 92.54 . . .
. . . The mother, however, argues that certain sections of the Florida Evidence Code [§§ 92.53 and 92.54, Fla.Stat . . . limited right to cross examine the child witness with assistance from an interpreter. §§ 92.53(4), (5), 92.54 . . . In support of this point, the mother urges at some length the applicability of Sections 92.53, 92.54, . . .
. . . television outside of appellant’s physical presence the court complied with the requirements of section 92.54 . . . The concurring opinion in Coy expressly cited section 92.54, Florida Statutes, as an example of an appropriate . . . The court fully complied with the requirements of section 92.54 in the present case, and appellant’s . . .
. . . trial or proceeding in which such witness testifies by use of closed circuit television pursuant to s. 92.54 . . .
. . . Section 92.54 — Use of closed circuit television in proceedings involving sexual offenses against victims . . .
. . . . §92.54(4) (1987); Mass. Gen. Laws §278:16D(b)(l) (1986); N. J. Stat. . . .
. . . trial or proceeding in which such witness testifies by use of closed circuit television pursuant to s. 92.54 . . .
. . . . § 1781; 22 CFR 92.49, 92.54; Rule 28(b), Rules of Civil Procedure; 2 Hackworth, Digest of International . . .
. . . to a foreign court asking that the witness be examined by the court. 28 U.S.C. 1781; 22 CFR 92.49, 92.54 . . .
. . . Mackenzie, and in the case of every item but one of $92.54 it was shown to have been withdrawn for the . . .