Anthony Spann v. State of Florida

Summary

The court affirmed the denial of Spann’s successive postconviction motion seeking a new trial based on an accomplice’s recantation. Applying a highly deferential review of the trial court’s credibility determination, the court held that competent, substantial evidence supported finding the recantation untruthful and unreliable. The record included timeline inconsistencies, conflicts with other evidence, lack of corroboration, and the witness’s demeanor and prior statements.