Lennart S. Koo, Petitioner v. State of Florida, Respondent

Summary

The Florida Supreme Court affirmed the First District Court of Appeal, holding that the trial court did not abuse its discretion in denying Koo’s motion for a new trial because the victim’s post‑trial letter did not constitute a recantation and therefore was not newly discovered evidence. The Court quashed the lower court’s erroneous statement of law that the letter was known to the parties.