Case Involving State's Failure to Disclose Evidence from a Crime Scene Photos

In Hoffman v. State, 800 So. 2d 174, 178 n.3 (Fla. 2001), the State failed to disclose the result of the analysis of hairs found clutched in the victim's hand. In Hoffman the analysis not only excluded the defendant as the source of the hair, but also excluded the victim and the codefendant. Id. at 179. As the court noted in that case: Whether Hoffman was in fact at the crime scene was an important issue that the jury had to resolve. Therefore, any evidence tending to either prove or disprove this fact would be highly probative. Hair evidence found in the victim's clutched hand could tend to prove recent contact between the victim and a person present at the crime scene at the time of her death. With the evidence excluding Hoffman as the source of the clutched hair, defense counsel could have strenuously argued that the victim was clutching the hair of her assailant, but that assailant was not Hoffman. Id. at 180.