Court OKs use of traffic tickets as evidence
Published: Saturday, January 14, 2006 at 6:01 a.m.
Last Modified: Friday, January 13, 2006 at 11:41 p.m.
TALLAHASSEE - The Florida Supreme Court ruled 4-3 Thursday that traffic citations were admissible in trials despite a law that plainly indicated just the opposite.
The case, Maddox v. State of Florida, began with an October 2001 traffic stop in Polk County when a deputy sheriff pulled over Robert Edwin Maddox for an improper lane change.
Maddox gave the officer the name and birth date of his brother and a subsequent search of the car found Maddox's identification card that gave his real name. A check found that his driver's license was suspended.
The officer kept the two citations that bore the name of Maddox's brother, and Maddox was eventually found guilty of two charges of forgery and two counts of uttering a forged document.
Maddox's attorney argued that the citations were inadmissible as evidence since a Florida law said, "citations shall not be admissible evidence in any trial."
The Supreme Court decision is an academic exercise to some degree. Lawmakers last year changed the law so traffic citations are admissible in forgery cases or as forensic evidence.
The majority opinion, which did not list its author, said "it is clear to us that the Legislature surely did not intend for the phrase 'any trial' to be construed so literally to exclude the use of traffic citations in all judicial proceedings.
"Such a sterile literal interpretation should not be adhered to when it would lead to absurd results," the majority opinion concluded, saying that a strict interpretation could mean that a traffic citation found at a murder scene couldn't be used as evidence.
The dissent opinion, written by Justice Raoul Cantero, said the statute was "as clear, definite and unambiguous as statutory language gets" and that judges had no power to add their own interpretations by floating the fear of "absurd" consequences.
"If expanded beyond rational basis review, the absurdity exception would threaten to undermine the separation of powers by allowing judges to substitute their own views of wise public policy for the compromises struck by legislators," Cantero wrote.
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