FIRST DISTRICT COURT OF APPEAL
STATE OF FLORIDA
No. 1D2025-0520
ISAAC MITCHELL WILLIAMS,
Appellants,
v.
STATE OF FLORIDA,
Appellees.
On appeal from the Circuit Court for Levy County.
William E. Davis, Judge.
October 28, 2026
OSTERHAUS, C.J.
Isaac Williams appeals his conviction and life sentence for first degree murder. He argues that the trial court should be reversed for its rulings on two discovery-related issues and that the State’s closing argument vitiated the fundamental fairness of his trial. We affirm and write to address the discovery issues.
Briefly stated, the State charged Williams with shooting and killing the victim aided by a driver accomplice. On the day of the murder, multiple witnesses placed Williams as a passenger in the white Ford vehicle used by the assailants. Williams’s defense focused on impugning the driver who testified against him and a claim that a third man was also involved in the crime. Williams argues that two discovery violations prejudiced his ability to make out this defense.
A.
Williams’s first argument involves video recordings of interviews of the driver-accomplice with law enforcement. In discovery filings more than a year before trial, the State disclosed the existence of recorded interviews of the driver after the shooting. The second of these video-recorded interviews didn’t make it into the state attorney’s file. When Williams’s lawyers asked for this video, they were told that the prosecution didn’t have it. Once the trial began, defense counsel sent an investigator to the sheriff’s office with a public records request seeking the video. The sheriff’s office found the video and handed it over to the defense investigator and prosecution. Evidently, the sheriff’s office had the video all along, but a mix-up caused it not to be delivered over to the prosecutor. The upshot was that the video of the witness’s second interview only surfaced for both parties after the trial began. Williams asserted that the delay in receiving the second interview video constituted a discovery violation causing him procedural prejudice and requiring a full Richardson hearing. See Richardson v. State, 246 So. 2d 771 (Fla. 1971) (establishing a defendant’s right to a hearing after a discovery violation).
When a discovery violation is alleged “the trial court initiates the Richardson inquiry as follows: 1) the court must determine whether a discovery rule has been violated; and 2) if the court finds a violation, it must assess whether the violation was inadvertent or willful, trivial or substantial, and whether it has prejudiced the opposing party's ability to prepare for trial.” Parker v. State, 225 So. 3d 1008, 1010 (Fla. 1st DCA 2017). “The threshold question . . . is whether there was a discovery violation.” Curry v. State, 1 So. 3d 394, 398 (Fla. 1st DCA 2009). “If the court correctly determine[s] that there was no violation, there would be no need for a [full] hearing.” Id.
Williams argues on appeal that “[t]he court conducted an inadequate Richardson hearing in this case by failing to consider or determine whether the violation was trivial or substantial” and by failing “to require the state to demonstrate the lack of procedural prejudice.” The trial court addressed the late-delivered
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video issue by conducting two hearings about the late-delivered video. Ultimately, it determined there was no discovery violation nor need for a full Richardson inquiry because the prosecutor didn’t have the recording and the State had disclosed its existence to defense counsel long before trial, months before defense counsel’s successful public records request. The State’s early disclosure of the second interview to the defense also included a summary of the interview giving notice of inconsistencies in the witness’s statements to law enforcement. Upon finding no discovery violation, the trial court gave defense counsel extra time to review the video and to prepare for its cross-examination of the witness.
Williams’s appellate argument that the trial court conducted an inadequate Richardson hearing fails to properly account for the trial court’s threshold finding of no discovery violation. See Pender v. State, 700 So. 2d 664, 667 (Fla. 1997) (noting the abuse of discretion standard applicable to the review of decisions finding no discovery violation). The problem with this argument is that a full Richardson hearing is not required unless there is a discovery violation. Curry, 1 So. 3d at 398. In other words, a full Richardson hearing wasn’t required here in the absence of a discovery violation. Because Williams doesn’t challenge the trial court’s ruling of no discovery violation, we must presume that this threshold decision was correct. See Applegate v. Barnett Bank of Tallahassee, 377 So. 2d 1150, 1152 (Fla. 1979) (describing the presumption of correctness attached to trial court decisions). And so, we reject Williams’s challenge to the adequacy of the Richardson hearing.
Williams likewise fails to demonstrate error in the trial court’s decision to deny a mistrial or continuance. Here, Williams’s argument provides no legal authority or discussion of the standard for granting a mistrial or continuance. Such “single-sentence, nonsupported, and non-elaborated ‘argument’” is not properly presented for appellate review. Jackmore v. Est. of Jackmore, 145 So. 3d 170, 171 (Fla. 1st DCA 2014); see also Henderson v. State, 569 So. 2d 925, 927 (Fla. 1st DCA 1990) (declining to consider an issue on appeal where “[n]o case law or other authority is cited to support [the appellant’s] contention”).
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B.
Williams’s second argument is that the State committed a discovery violation by not notifying the defense of an oral statement by a defense witness that allegedly contradicted a prior recorded statement to law enforcement officers. If a witness gives a recorded statement, the State must disclose to the defense any oral statement that is materially different from the recorded statement. Andres v. State, 254 So. 3d 283, 293 (Fla. 2018). The “[f]ailure to disclose an oral statement which constitutes a material change to a witness’s recorded statement is a discovery violation that triggers a full Richardson hearing.” Id.
According to the evidence here, the defense witness saw the white Ford used in the crime multiple times on the day of the shooting, while playing dominoes across the street from a Williston gas station. According to the witness’s initial statement to police after the shooting, the driver, Williams, and a third man—all three of whom the witness knew—visited the gas station in the white Ford ten minutes before the shooting. But when questioned later by police and shown a video from the gas station, the witness changed the timing of her recollection. Specifically, she claimed to see all three men in the white Ford at the gas station earlier in the day, but only seeing the driver ten minutes before the shooting. During this last gas station visit, she couldn’t see if there were other passengers in the vehicle because of tinted windows. Based on the new timing information about when she saw all three men in the car, Williams requested a Richardson hearing for a discovery violation. But the trial court denied the request. Williams then proceeded to put the defense witness on the stand and to tie all three men to the white Ford on the day of the shooting.
We see no reversible error in the court’s ruling under these facts for a couple of reasons. First, the witness’s statement didn’t materially change her initial recorded statement to law enforcement. Rather, the witness’s testimony continued tying all three men to the white Ford on the day of the shooting, even if the witness couldn’t affirmatively identify who was in the car, besides the driver, when she saw it the last time before the shooting. The defense’s argument and ability to use the witness to make its case
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remained essentially unchanged. In fact, the defense still called the witness whose testimony continued to support its theory of the case. As Williams’s closing argument recognized, her testimony did not diminish the possibility that all three men remained in the car when she saw it ten minutes before the shooting:
[The driver] claims it was just [Williams] in that car. But,
again, you heard from [the witness] . . . that [the third
man] was in the backseat of that car. You heard the same
thing from Mr. Williams. Mr. Williams provided you more
information because Mr. Williams was there. [The third
man] was there the entire time in the backseat of the car.
Furthermore, Williams’s opening statement, before he knew of the witness’s changed statement, focused on the driver’s credibility. Williams aimed to establish that the driver’s damaging testimony was aimed to deflect from his own culpability. As to the driver, the witness’s recorded statement didn’t change at all from consistently confirming his presence in the car. For these reasons, we see no reasonable probability that the defense was materially prejudiced or hindered in its trial preparation or strategy. See Scipio v. State, 928 So. 2d 1138, 1149 (Fla. 2006) (describing the harmless error standard); see also Curry, 1 So. 3d at 399 (“A conviction may be affirmed despite an error in denying a Richardson hearing only if the reviewing court concludes beyond a reasonable doubt that the error did not result in procedural prejudice.”).
We AFFIRM the judgment and sentence.
LEWIS and BILBREY, JJ., concur.
Not final until disposition of any timely and
authorized motion under Fla. R. App. P. 9.330 or
9.331.
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Jessica J. Yeary, Public Defender, and Danielle Jorden, Assistant Public Defender, Tallahassee, for Appellants.
James Uthmeier Attorney General, and Miranda L. Butson, Assistant Attorney General, Tallahassee, for Appellees.
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