Staten v. State

In Staten v. State, 519 So. 2d 622 (Fla. 1988), the Court held that an individual cannot be convicted as both a principal and an accessory after the fact based on the same criminal act because the crimes are mutually exclusive. Id. at 623, 625. In reaching this conclusion, the Court only cursorily stated that "double jeopardy is not implicated here" and referenced three decisions without elaboration or analysis. Id. at 625. The Court then explained that whether dual convictions under the principal and accessory offenses are permissible would be based "solely on a construction of the crime of being an accessory after the fact." Id. The Court did not explain why principles of double jeopardy were not implicated, and it certainly did not broadly hold that dual convictions under mutually exclusive statutes can never implicate double jeopardy.