Leonardo Marrero v. State of Florida

Petitioner requested a judgment of acquittal on the charge of felony criminal mischief where defense counsel argued that the state failed to establish a prima facie case that the damage to the doors that petitioner drove into was one thousand dollars or more, the threshold amount for the felony charge. At issue was whether the Third District Court of Appeal properly relied on a "life experience" exception to the general rule that a state must establish the amount of damage to prove felony criminal mischief. The court quashed the Third District's decision, disapproved of Jackson v. State, and other decisions in this context that applied to the "life experience" exception and held that before a defendant could be convicted of felony criminal mischief, the state must prove the amount of damage associated with the criminal conduct.