## Facts

- Richard L. Dixon was stopped for a traffic infraction.
- During the stop, Dixon gave the officer a false name.
- The officer issued uniform traffic citation(s) in the false name, and Dixon signed the citation(s) using that false name.
- After the false name was discovered, the State charged Dixon by information with forgery of a written instrument under section 831.01, Florida Statutes (2000), and driving without a valid driver’s license.
- The State’s forgery theory depended on introducing the traffic citation itself as the allegedly forged “written instrument.”
- Dixon moved in limine to exclude the citation under section 316.650(9), Florida Statutes, which stated that a uniform traffic citation “shall not be admissible evidence in any trial.”
- The trial court denied the motion, admitted the citation, and Dixon was convicted of forgery and driving without a valid license.

## Issues

1. Whether section 316.650(9), Florida Statutes, barred admission of a uniform traffic citation as substantive evidence in a criminal trial for forgery where the citation was the alleged forged instrument.
2. Whether the trial court’s admission of the citation required reversal of Dixon’s convictions.

## Decision

- The First District Court of Appeal reversed Dixon’s convictions and remanded.
- The court held that the plain language of section 316.650(9) prohibits admission of a uniform traffic citation “in any trial,” including a criminal forgery prosecution based on that citation.
- The court rejected any implied exception for forgery cases because the statute contained no textual carve-out.
- Because the citation was central to the State’s proof of forgery, the erroneous admission was not harmless.

## Legal Principles

- When statutory language is clear and unqualified, courts apply its plain meaning rather than create judicial exceptions.
- Section 316.650(9), Florida Statutes, imposes a categorical evidentiary bar: a uniform traffic citation is not admissible evidence in any trial.
- A statutory prohibition on admissibility applies even when the document is offered as the alleged instrument of a charged offense, absent an express legislative exception.

## Conclusion

The appellate court held that a uniform traffic citation is inadmissible in any trial under section 316.650(9), including a prosecution alleging the defendant forged the citation by signing it under a false name; admitting the citation required reversal and remand.


Dixon v. State, 812 So. 2d 595 (Fla. 1st DCA 2002)