Joyce Angelo v. State of Florida

Appellant challenges her conviction for aggravated battery with a deadly weapon. She argues the trial court erred in prohibiting her from testifying regarding prior specific acts of violence committed by the victim. The State concedes that the trial court erred. We agree. See Savage v. State, 99 So.3d 1001, 1002-03 (Fla. 1st DCA 2012) (finding that pursuant to section 90.404(l)(b), Florida Statutes, once the defendant presents evidence that the victim committed an overt act at or near the time of the incident that reasonably indicated the need for self-defense, the defendant may present…