James Warmington, Petitioner v. State of Florida, Respondent

Summary

The court held that the State impermissibly shifted the burden of proof by eliciting testimony suggesting that Warmington had a duty to produce exculpatory documents during the investigation. Because the testimony could have led the jury to believe that Warmington had to prove his innocence, and the State could not establish beyond a reasonable doubt that the error did not affect the verdict, the court quashed the district court's decision and remanded for a new trial. Justice Polston and Justice Perry, dissenting, would have dismissed the review for lack of jurisdiction and concluded that the testimony was historical evidence that neither shifted the burden nor constituted harmful error.