Juan Bridon v. The State of Florida

Summary

The Third District Court of Appeal of Florida affirmed Juan Bridon's conviction in an appeal from the Miami-Dade County Court. The court held that the motion for judgment of acquittal issue was preserved and cited authority concerning criminal intent requirements for public welfare offenses and mala prohibita crimes.

Holdings

1. A motion for judgment of acquittal made at the close of the State's evidence preserves the issue for appeal; the defendant is not required to renew the motion after presenting evidence.
2. Certain public-welfare offenses and crimes proscribing conduct not prohibited at common law may not require proof of criminal intent.

Questions Presented

1. Whether a defendant preserves a judgment-of-acquittal issue by moving for acquittal at the close of the State's evidence without renewing the motion after presenting defense evidence.
2. Whether the offense at issue required proof of criminal intent.

Disposition

affirmed