Karls v. State of Florida: Appeals Court Reviews Exclusion of Evidence in DUI Trial

Karls v. State of Florida is a 2025 Florida DUI case involving an allegedly drunk driver who appealed his conviction for driving under the influence with property damage. According to the lawsuit, Karls crashed his motorcycle into a parked car after having a nap and dinner at his mother’s house. Upon arriving, the police believed that Karls was under the influence of alcohol primarily due to eyewitness accounts, bodycam footage, a failed field sobriety test, and a failed urine test. Karls was ultimately convicted of DUI causing property damage.

The appeal 

On appeal, Karls raised several issues, including the trial court’s decision to prevent his mother from testifying on his behalf about her observations of him before the accident. These observations, Karls argued, could have supported the argument that he wasn’t under the influence of drugs or alcohol when he left her house.

Initially, the trial court excluded the mother’s testimony on the basis that it was irrelevant due to a 30-minute gap between her last seeing him and the accident. Ultimately, however, the appeals court sided with Karls and ruled that his mother should have been allowed to testify on his behalf. The court emphasized that criminal defendants have the right to present relevant evidence and create reasonable doubt.

Ultimately, this case centered on the issue of what constitutes relevant evidence during a DUI case.

What constitutes relevant evidence in a Florida DUI case?

For a Florida DUI case, the legal standard for determining whether evidence is relevant or not is primarily defined by Florida Statute § 90.401, which states that “Relevant evidence is tending to prove or disprove a material fact.” In other words, the evidence must have a logical connection to a significant fact in the case and make the fact more or less probable than it would be without the evidence.

Relevance, however, isn’t the only standard for admitting evidence. Even when evidence is considered relevant, it can still be excluded under Florida Statute §90.403 if its probative value (or its usefulness in proving a point) is outweighed by the danger of:

• Unfair prejudice – Occurs when evidence potentially sways a jury’s opinion unfairly against a party.

• Confusion of issues – Occurs when evidence makes the case unclear or difficult to understand.

• Misleading the jury – If the evidence potentially leads the jury to make an incorrect conclusion, it can be excluded.

• Needless presentation of cumulative evidence – If the evidence is repetitive and unnecessary, it can be excluded.

When it comes to DUI cases, this means that even evidence that might seem related to the case could be excluded if it creates unfair bias or distracts the jury from core issues. For example, evidence of prior drug use might be excluded by a judge since it doesn’t directly relate to the alleged impairment at the time of the traffic stop and would unfairly prejudice the jury against the defendant.

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Source:

law.justia.com/cases/florida/second-district-court-of-appeal/2025/2d2024-0325.html