Tyler v. State
Florida Court of Appeals
131 So. 3d 811 (2014)
Relevant factsFree
Tyler (defendant), charged with armed robbery with a firearm, presented a duress defense at trial and received a jury instruction on duress, but the trial court declined to instruct the jury that the state bore the burden of proving beyond a reasonable doubt that Tyler did not act under duress; Tyler was convicted and appealed, analogizing duress to self-defense in arguing the state should have borne that burden.
IssueFree
Whether the defendant bears the burden of proving the affirmative defense of duress.