## Facts

- Michael Stoll was convicted of premeditated first-degree murder of his wife, Julie Stoll, for a homicide occurring on November 3, 1994, and was sentenced to death.
- The State’s primary witness, Christopher Stewart (19), testified that he killed Julie but did so at Stoll’s direction; Stewart claimed Stoll planned the murder and was present during the killing.
- Stoll testified, denied directing or assisting the killing, and admitted only involvement after the fact; he also acknowledged recent marital conflict related to a prior domestic-violence charge.
- The medical examiner testified the probable cause of death was strangulation due to severe head and neck trauma.
- The jury found Stoll guilty and recommended death by a 7–5 vote.
- The trial court imposed death after finding two aggravators (heinous, atrocious, or cruel; and cold, calculated, and premeditated) and several mitigators (including no significant prior criminal history), concluding aggravation outweighed mitigation.
- During trial, the State sought to introduce (1) Dana Martin’s testimony recounting Julie’s prior statements about Stoll’s threats and her fear, and (2) Julie’s written statement from an earlier domestic-violence proceeding.
- The trial court excluded Martin’s testimony on direct but admitted it in rebuttal; it also admitted Julie’s prior written statement from a court file.

## Issues

1. Whether the trial court erred by allowing the State to present Dana Martin’s rebuttal testimony recounting Julie Stoll’s out-of-court statements without establishing a hearsay exception.
2. Whether the trial court erred by admitting Julie Stoll’s prior written statement from an earlier domestic-violence proceeding as substantive evidence, including whether judicial notice of a court file could support admissibility.
3. Whether the admission of the hearsay evidence was harmless beyond a reasonable doubt.

## Decision

- The Florida Supreme Court reversed the conviction and vacated the death sentence.
- The court held Martin’s rebuttal testimony was inadmissible hearsay because the State failed to lay the foundation for any applicable exception (including excited utterance or state of mind).
- The court held Julie’s prior written statement was inadmissible hearsay and could not be admitted merely because it was contained in a judicially noticed court file.
- The court held the errors were not harmless beyond a reasonable doubt because the improperly admitted statements likely contributed to the verdict.
- The case was remanded for a new trial.

## Legal Principles

- Hearsay is inadmissible unless a recognized exception applies, and the proponent must establish the factual predicate for the exception.
- The excited-utterance exception requires a sufficient showing that the statement was made under the stress of a startling event; generalized accounts of past threats or abuse ordinarily do not satisfy this foundation.
- The state-of-mind exception does not permit admission of accusatory historical assertions about a defendant’s past acts when offered to prove the truth of those assertions; statements of fear must be carefully limited to permissible purposes.
- Judicial notice of a prior court file may establish the existence and procedural status of prior proceedings, but it does not make the factual assertions within prior filings admissible in a later trial.
- Under Florida’s harmless-error test, the State must prove beyond a reasonable doubt that an error did not contribute to the verdict; highly prejudicial hearsay bearing on intent and motive will rarely be harmless where the case turns on contested credibility.

## Conclusion

The Florida Supreme Court ordered a new trial because the State introduced highly prejudicial victim statements through inadmissible hearsay—both via rebuttal testimony and a prior written statement—without a valid exception, and the State failed to show beyond a reasonable doubt that these errors did not affect the jury’s verdict.


Stoll v. State, 762 So. 2d 870 (Fla. 2000)