State v. Titus

The State seeks certiorari relief following the trial court’s June 23, 2011 order granting defendant Subi Titus’s motion to disclose the identity of a confidential informant. Titus did not file an affidavit until July 27, 2011 — one month after the order issued. The trial court never considered sworn allegations. We, therefore, find that the trial court departed from the es*764sential requirements of the law when it granted disclosure without having sworn allegations of a legally cognizable defense before it. State v. Carter, 29 So.3d 1217, 1219 (Fla. 2d DCA 2010). We make no determination of…