## Facts

- Antwan J. Tyler was charged in Florida circuit court with armed robbery with a firearm.
- Tyler raised the affirmative defense of duress, asserting he participated due to threats or coercion.
- The trial court gave the standard jury instruction on duress.
- The jury instructions did not expressly state that the State had to prove beyond a reasonable doubt that Tyler did not act under duress.
- Tyler was convicted and appealed, arguing the duress instruction was fundamentally erroneous and relying on an asserted reading of Mosansky v. State.

## Issues

1. Whether giving the standard duress instruction without explicitly stating the State must disprove duress beyond a reasonable doubt constituted fundamental error.
2. Whether Mosansky v. State required reversal when an affirmative-defense instruction omits an express burden-allocation statement, even if the charge as a whole states the State’s general burden.

## Decision

- The First District Court of Appeal affirmed Tyler’s conviction and sentence.
- The court held that the duress instruction’s omission of an explicit statement that the State must disprove duress beyond a reasonable doubt was not fundamental error in this case.
- The court clarified that Mosansky did not create a per se rule requiring express burden language in every affirmative-defense instruction; Mosansky addressed instructions that misled the jury by shifting the burden to the defendant.
- Reviewing the jury instructions as a whole, the court concluded the charge adequately conveyed the presumption of innocence and the State’s burden to prove guilt beyond a reasonable doubt and did not suggest Tyler had to prove duress.

## Legal Principles

- In Florida, once a defendant presents evidence supporting an affirmative defense such as duress, the State bears the burden to disprove the defense beyond a reasonable doubt.
- Jury instructions are evaluated as a whole; an omission in one instruction is not necessarily reversible if the overall charge correctly conveys the State’s burden and does not mislead jurors about burden allocation.
- Fundamental error in jury instructions is limited to errors that undermine the validity of the trial or are so misleading on a disputed matter that they deprive the defendant of a fair trial.
- An instruction that shifts or implies shifting the burden of persuasion on an affirmative defense from the State to the defendant may constitute fundamental error; a mere failure to restate the burden in the specific defense instruction generally does not.

## Conclusion

The court affirmed because the instructions, read together, did not mislead jurors into believing the defendant bore the burden to prove duress, and the omission of an explicit burden-to-disprove-duress statement in the duress instruction did not meet Florida’s narrow standard for fundamental error.


Tyler v. State, 131 So. 3d 811 (Fla. Dist. Ct. App. 1st Dist. 2014)