Chaffin v. State
Decision Date | 14 August 2013 |
Docket Number | No. 4D11-4572,4D11-4572 |
Parties | TYSON L. CHAFFIN, Appellant, v. STATE OF FLORIDA, Appellee. |
Court | Florida District Court of Appeals |
Tyson L. Chaffin appeals his convictions and sentences for second degree murder and tampering with evidence. He makes the following arguments on appeal: 1) the trial court erred in denying his motion for judgment of acquittal; 2) the trial court erred in denying his motion to suppress his pre-arrest statements; 3) the trial court gave an erroneous jury instruction on justified use of force; and 4) the State created fundamental error by submitting two separate incidents of tampering to the jury. We reverse the tampering conviction but affirm the second degree murder conviction.
This is a particularly sad case involving a patricide that was allegedly committed in self-defense. On August 1, 2009, Chaffin (then 26 years old) fatally shot his father at their home. At the time of the fatal encounter, Chaffin's father was in a drunken rage over the fact that Chaffin's girlfriend threatened to call the police and inform them that the father was operating a marijuana grow house at the home. As a result of the threat, the father disassembled the grow house and kicked Chaffin out of the home. While Chaffin was in his bedroom gathering his belongings, his father, who was wearing a gun holstered to his hip, continuously yelled at Chaffin from outside the home, accusing Chaffin of ruining his life. Chaffin maintained that his father was acting aggressively and was ripping the siding off of the home. Allegedly fearing that his father was going to shoot him, Chaffin took a gun out of his bedroom closet, aimed it out of the window, and fatally shot his father inthe head. Chaffin then put his father's body in a wheelbarrow, wheeled it into the backyard, and buried it. He also burned his clothing and cleaned up the area where his father was shot. He claimed he covered up the shooting instead of calling the police out of fear that he would be arrested for the grow house activity.
About two weeks later, police received a tip that Chaffin killed his father and paid a visit to the home. There, they encountered Chaffin's mother, who told the police that they needed to speak with Chaffin. The mother called Chaffin and he agreed to meet them at the police station. Upon arriving at the police station, Chaffin was brought to an interview room with a camcorder running and was immediately read his Miranda1 rights. Before and after he was read his rights, one of the interviewing detectives referred to the rights as a "formality." Chaffin repeatedly acknowledged that he understood his rights and wished to speak to the detectives and read and signed the Miranda waiver form. After he signed the waiver, a detective again asked Chaffin if he understood his rights, to which Chaffin responded: "Uh, basically I have a right to an attorney, right?" The officers proceeded with questioning, and Chaffin confessed to killing his father and burying him in the backyard, maintaining that he did so because he was scared for his life and was sure that his father was going to pull his gun and shoot at him if given the opportunity. Chaffin later filed a motion to suppress his statements which the trial court denied.
Chaffin was charged by information with one count of first degree murder and one count of tampering with evidence. The information did not provide a factual basis for the tampering charge, and when asked by the court for clarification as to whether the charge went to concealing the grow house or burying the father's body, the State represented that "it could be either one." The case proceeded to a jury trial, where the primary issue for the jury to consider was whether Chaffin acted in self-defense. Chaffin moved for a judgment of acquittal on all counts, which the trial court denied. After considering all of the evidence, which included Chaffin's confession and testimony, testimony from the investigating officers, and testimony from Chaffin's mother and family friends regarding the father's temperament and behavior, the jury found Chaffin guilty of the lesser included offense of second degree murder and of tampering with evidence. This appeal follows.
Although we are only reversing Chaffin's tampering conviction, we also write to set forth our reasoning for affirming the trial court's denial of Chaffin's motion for judgment of acquittal on the second degree murder conviction and his motion to suppress his confession. We affirm on the remaining issues raised by Chaffin without comment.
Chaffin asserts that the trial court erred in denying his judgment of acquittal because the State failed to rebut his theory of self-defense and the evidence did not support a second degree murder conviction. After carefully reviewing the record, we hold that there was no error.
When reviewing a trial court's decision on a motion for judgment of acquittal, the appellate court applies a de novo standard of review. Romero v. State, 901 So. 2d 260, 264 (Fla. 4th DCA 2005). In Johnston v. State, 863 So. 2d 271 (Fla. 2003), the Florida Supreme Court reviewed the principles that govern a motion for judgment of acquittal:
Generally, an appellate court will not reverse a conviction that is supported by competent, substantial evidence. There is sufficient evidence to sustain a conviction if, after viewing the evidence in the light most favorable to the State, a rational trier of fact could find the existence of the elements of the crime beyond a reasonable doubt. "A motion for judgment of acquittal should be granted in a circumstantial evidence case if the [S]tate fails to present evidence from which the jury can exclude every reasonable hypothesis except that of guilt." "The question of whether the evidence fails to exclude all reasonable hypotheses of innocence is for the jury to determine, and where there is substantial, competent evidence to support the jury verdict, we will not reverse." In meeting its burden, the State is not required to "rebut conclusively, every possible variation of events" which could be inferred from the evidence, but must introduce competent evidence which is inconsistent with the defendant's theory of events. Once the State meets this threshold burden, it becomes the jury's duty to determine whether the evidence is sufficient to exclude every reasonable hypothesis of innocence beyond a reasonable doubt.
Id. at 283 (internal citations omitted).
When the defendant claims self-defense in a murder case, the state is required to prove that the defendant did not act in self-defense beyond a reasonable doubt. Rasley v. State, 878 So. 2d 473, 476-77 (Fla. 1st DCA 2004). "If a defendant establishes a prima facie case of self-defense, the state must overcome the defense by rebuttal, or by inference in its case in chief." State v. Rivera, 719 So. 2d 335, 337 (Fla. 5th DCA 1998). "Under Florida law, a person is justified in using deadly force in self-defense when he or she reasonably believes such force is necessary to prevent imminent death or great bodily harm . . . ." Michel v. State, 989 So. 2d 679, 681 (Fla. 4th DCA 2008). "The law does not ascribe a subjective standard as to a defendant's state of mind, but concerns a reasonably prudent person's state of mind." Reimel v. State, 532 So. 2d 16, 18 (Fla. 5th DCA 1988). Further, "[t]he question of self-defense is one of fact, and is one for the jury to decide where the facts are disputed." Dias v. State, 812 So. 2d 487, 491 (Fla. 4th DCA 2002).
Here, the State presented sufficient evidence to create a jury question regarding Chaffin's self-defense claim. First, Chaffin's version of the events was not entirely corroborated by the evidence as testimony of one of the investigating officers contradicted Chaffin's story that the father was ripping the siding off of the Home right before he was shot. Second, the evidence created a fact issue as to whether a reasonable person in Chaffin's shoes would have believed danger was imminent — during his videotaped confession Chaffin admitted that his father never stated he was going to shoot or kill him, and his father did not ever reach for his gun. Finally, Chaffin's actions after the shooting consisted of concerted efforts to cover up his actions. He cleaned up the area where he shot his father, buried his father in the backyard, and burned any remaining evidence. These efforts run contrary to Chaffin's self-defense argument, and created a jury issue. Bogart v. State, 114 So. 3d 316, 318 (Fla. 4th DCA 2013) ( ).
Likewise, the evidence presented by the State supported Chaffin's conviction for second degree murder. Section 782.04(2), Florida Statutes (2009), provides "[t]he unlawful killing of a human being, when perpetratedby any act imminently dangerous to another and evincing a depraved mind regardless of human life, although without any premeditated design to effect the death of any particular individual, is murder in the second degree . . . ." § 782.04(2), Fla. Stat. (2009).
"In the context of second-degree murder, an act is imminently dangerous to another and evinces a 'depraved mind' if it is an act or series of acts that: (1) a person of ordinary judgment would know is reasonably certain to kill or do serious bodily injury to another; and (2) is done from ill will, hatred, spite or an evil intent; and (3) is of such a nature that the act itself indicates an indifference to human life." Wiley v. State, 60 So. 3d 588, 591 (Fla. 4th DCA 2011).
As we have explained, "[p]ointing a loaded gun at the head of the victim and then firing has frequently been held to be an act 'imminently dangerous to another...
To continue reading
Request your trial