Cowan v. State
Cases that cite this one
2 later published cases cite this decision. The 1 that cite it most often are listed here.
- Ronald Lee Coleman v. State of Florida (Fla. Dist. Ct. App. 2020)
This list shows which later cases cite this one. It does not say how they treated it, and no review of that has been done. Not a substitute for Shepard’s or KeyCite — verify before relying.
Opinion of the Court
In this direct appeal, appellant claims the trial court erred by failing to make the required findings of reliability pursuant to section 90.803(23), Florida Statutes (2009), when it ruled the child victim’s out-of-court statements were admissible at trial. We agree with the state that this claim is not preserved for appeal because appellant failed to make a contemporaneous objection to the lack of findings. Elwell v. State, 954 So.2d 104, 109 (Fla. 2d DCA 2007); accord, Rodriguez v. State, 120 So.3d 656 (Fla. 1st DCA 2013); McCloud v. State, 91 So.3d 940, 941 (Fla. 1st DCA 2012). Accordingly, we affirm.
AFFIRMED.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.