MCCOY v. STATE (2026)

District Court of Appeal of Florida, Third District.

Stephen Alexander Gonzales MCCOY, Appellant, v. STATE of Florida, Appellee.

No. 3D24-1038

Decided: January 14, 2026

Before SCALES, C.J., and MILLER and BOKOR, JJ.

Carlos J. Martinez, Public Defender, and Susan S. Lerner, Assistant Public Defender, for appellant. James Uthmeier, Attorney General, and Camilo Montoya, Assistant Attorney General, for appellee.

Affirmed. See State v. Richards, 843 So. 2d 962, 965 (Fla. 3d DCA 2003) (recognizing that if there has been a recantation, the State generally may impeach its own witness with a prior inconsistent statement where the State calls the witness with the reasonable expectation that the witness will testify to something helpful to the State's case aside from the prior inconsistent statement); see also Valentine v. State, 307 So. 3d 726, 737 (Fla. 4th DCA 2020) (concluding that any error resulting from a witness's hearsay identification of the defendant in a surveillance video was harmless, in part, because the defendant's face could be seen in the video and the jury viewed the video).

PER CURIAM.

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