Whether the standard jury instruction on duress was fundamentally erroneous because it did not expressly require the State to disprove duress beyond a reasonable doubt.
Holding
No. The instruction was not erroneous, fundamentally or otherwise, because neither Florida precedent nor constitutional doctrine requires the State to bear or be expressly instructed on a burden to disprove duress beyond a reasonable doubt.
Reasoning
Tyler relied on an analogy between duress and self-defense, contending that both are justification or excuse defenses and therefore should receive the same type of reasonable-doubt instruction. But the standard self-defense instruction does not say that the burden of proof shifts to the State. It instead tells jurors to acquit if they have a reasonable doubt whether the defendant was justified in using deadly force.
Tyler also misread Mosansky v. State. In Mosansky, the court expressly rejected the claim that a trial court must specifically instruct the jury that the State has the burden to prove beyond a reasonable doubt that the defendant did not act in self-defense. Thus, Mosansky did not support Tyler's proposed burden-shifting instruction for duress.
The court also relied on Dixon v. United States, in which the United States Supreme Court explained that duress permits a defendant to avoid liability because coercive conditions may excuse otherwise culpable conduct, even when the required mens rea exists. Dixon held that the Constitution does not require the government to disprove duress beyond a reasonable doubt.
Historically, duress has been treated as an affirmative defense, with the defendant bearing the burden to establish circumstances of justification, excuse, or mitigation. That allocation also fits the ordinary evidentiary principle that the party with peculiar access to the relevant facts bears the burden of proving them. Accordingly, the challenged duress instruction did not improperly shift or omit a burden belonging to the State.