State of Florida, Petitioner v. Joseph Eugene McFadden, Respondent

Summary

The court held that Florida's criminal-discovery rule does not require disclosure of an oral, unrecorded witness statement when it does not materially alter a previously disclosed written or recorded statement. Because the sister's undisclosed statement that a shotgun had been kept in the house was not a material departure from her deposition testimony, no discovery violation occurred and no Richardson hearing was required. Justice Lewis, dissenting, would have required an inquiry into whether the statement was recorded elsewhere and whether a discovery violation occurred.