Carroll v. State

HERSEY, Judge.

The trial court sustained a state objection and excluded defense photographic exhibits without conducting a Richardson hearing. (Richardson v. State, 246 So.2d 771 (Fla.1971)). Since “[a] Richardson inquiry is designed to ferret out procedural prejudice occasioned by a party’s discovery violation,” Smith v. State, 872 So.2d 86, 88 (Fla.1979), it is a mandatory component of the trial court’s decision-making process. Failure to conduct a Richardson inquiry requires automatic reversal. Smith v. State, supra; Kilpatrick v. State, 376 So.2d 386 (Fla.1979); Cumbie v. State, 345 So.2d…