Lawrence William Patterson v. State of Florida

In two vehicle arson cases, our First and Fourth District Courts of Appeal reached conflicting decisions regarding the due process implications of admitting the testimony of State experts who physically examined the vehicle prior to its destruction where the defendant’s expert did not have that opportunity. Compare Patterson v. State, 153 So.3d 307 (Fla. 1st DCA 2014) (finding no due process violation), with Lancaster v. State, 457 So.2d 506 (Fla. 4th DCA 1984) (finding due process violation). 1 Applying the well-established rule from Arizona v. Youngblood, 488 U.S. 51, 109 S.Ct. 333, 102…