Carlos Couto v. State of Florida

Summary

The Third District Court of Appeal of Florida affirmed Carlos Couto’s conviction and sentence for first-degree grand theft. The court held that the trial court acted within its discretion in limiting defense counsel’s cross-examination of the victim and closing argument because the questioning was not relevant to the defense theory and the argument exceeded the scope of the evidence.

Holdings

1. The trial court did not abuse its discretion by limiting defense counsel's cross-examination of the victim because the questioning concerned an area neither germane to the victim's testimony nor relevant to Couto's theory of defense.
2. The trial court did not abuse its discretion by limiting defense counsel's closing argument because the argument was outside the scope of the evidence.

Questions Presented

1. Whether the trial court abused its discretion by limiting defense counsel's cross-examination of the victim.
2. Whether the trial court abused its discretion by limiting defense counsel's closing argument.

Disposition

affirmed