Churchill v. State
Annotate this CasePrior to trial, Petitioner filed a motion in limine seeking to exclude witness testimony about the identity of the substances found at the scene of his arrest and the results from the chemical field tests performed on those substances, arguing that the witnesses were not qualified to testify as expert witnesses. The trial court denied the motion, concluding that the officer who performed the chemical field tests and identified the methaphetamine was sufficiently qualified to testify as an expert witness. Petitioner then entered an open plea of no contest to charges of conspiracy to manufacture methamphetamine, manufacture of methamphetamine, and possession of a listed chemical, reserving his right to appeal the ruling on the motion in limine, which the State agreed was dispositive of the case. Petitioner appealed, arguing that the challenged evidence failed to comply with the standard for admissibility in Daubert. The Fifth District Court of Appeal dismissed Petitioner’s appeal for lack of jurisdiction, concluding that the trial court’s order was not dispositive and therefore could not be challenged on direct appeal. The Supreme Court quashed the Fifth District’s decision, holding that, in appeals from conditional no contest pleas, stipulations of dispositiveness are binding on the appellate court. Remanded.
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