Livingston v. State

MORRIS, Judge.

Fredrick Livingston appeals his conviction after a jury trial for the offense of robbery, raising several issues that we have determined to be without merit. We affirm his conviction and sentence, but we write to address the trial court’s admission into evidence of two out-of-court descriptions of the suspect received by deputies on the night of the offense.

At trial, the State presented the testimony of three witnesses: the victim and two sheriffs deputies. The victim first testified that at approximately 7:20 in the evening on December 21, 2012, he was walking to catch the bus…