Antron Colston v. State of Florida

Summary

The First District Court of Appeal of Florida affirmed Antron Colston’s convictions and life sentence for first-degree murder and armed robbery. The court held that GPS records containing handwritten markings were admissible under the business-records exception and that username information from cell phones was not inadmissible hearsay.

Holdings

1. The handwritten marks did not make the GPS exhibit inadmissible under the hearsay rule or remove it from the business-records exception because Colston identified no authority prohibiting such marks on a business record and no record evidence showed that the marks were not made in the ordinary course of a regularly conducted business activity.
2. The username information was not inadmissible hearsay because it was not established that the information was offered to prove the truth of a matter asserted, and the court rejected the argument that a username necessarily constitutes a statement establishing ownership.

Questions Presented

1. Whether handwritten marks on GPS-record screenshots rendered the exhibit inadmissible hearsay despite the business-records exception.
2. Whether username information, including an email address incorporating the victim's name, constituted inadmissible hearsay.

Disposition

affirmed