Bryant — Certiorari denied in dispute over examination by state-requested expert

Case
Christopher Bryant v. State of Florida
Court
Florida Third District Court of Appeal
Judge
Lindsey; Miller; Rebull
Date Decided
October 23, 2026
Docket No.
3D26-2261
Topics
Criminal Procedure; Expert Examination; Certiorari
Source
Read the full opinion

Background

Christopher Bryant petitioned for a writ of certiorari seeking review of a ruling by the Circuit Court for Miami-Dade County in criminal case number F18-25455C. The appellate opinion does not describe the underlying charges or specify the details of the challenged ruling.

The authorities cited by the Third District concern Florida Rule of Criminal Procedure 3.203(c), including the trial court’s obligation to appoint an expert selected by the state attorney upon request and the consequences addressed by the rule when a defendant refuses examination or full cooperation with appointed experts or the State’s expert.

The Court’s Holding

The Third District Court of Appeal denied Bryant’s petition for writ of certiorari. Its per curiam opinion provided no extended analysis.

The court cited rules requiring appointment of an expert chosen by the state attorney when requested and addressing a defendant’s refusal to undergo or cooperate with an expert examination. It also cited State v. Zapetis, Dillbeck v. State, and State v. Hickson as supporting authority.

Key Takeaways

  • The Third District denied certiorari relief and left the circuit court’s ruling undisturbed.
  • Florida Rule of Criminal Procedure 3.203(c)(2) requires a court to appoint an expert chosen by the state attorney when the state attorney requests one.
  • The decision relies on authority addressing expert examinations and a defendant’s refusal to be examined or cooperate, but does not provide additional factual or legal analysis.

Why It Matters

The decision reinforces the mandatory language governing appointment of a state-selected expert under Rule 3.203(c). It also signals that objections involving a required examination or cooperation with such an expert will not necessarily support extraordinary certiorari relief.

Because the opinion is a brief denial without a factual discussion, its practical reach should be understood through the cited rule and cases rather than through any unstated circumstances of Bryant’s prosecution.

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