Eduardo Alfredo Medrano-Chavez v. State of Florida

Third District Court of Appeal
                               State of Florida

                          Opinion filed May 6, 2026.
       Not final until disposition of timely filed motion for rehearing.

                            ________________

                             No. 3D25-0800
                      Lower Tribunal No. F21-17488
                          ________________


                Eduardo Alfredo Medrano-Chavez,
                                  Appellant,

                                     vs.

                            State of Florida,
                                  Appellee.


     An Appeal from the Circuit Court for Miami-Dade County, Christine
Hernandez, Judge.

     Carlos J. Martinez, Public Defender, and Amy Weber, Assistant Public
Defender, for appellant.

    James Uthmeier, Attorney General, and Liz Feliz, Assistant Attorney
General, for appellee.


Before SCALES, C.J., and LOGUE and LOBREE, JJ.

     LOGUE, J.

     Eduardo Alfredo Medrano-Chavez appeals his convictions and
sentences for sexual activity with a child by a person in familial or custodial

authority (Count I) and lewd and lascivious molestation on a child between

12 and 16 years of age (Count II). We reverse Medrano-Chavez’s

convictions and sentences and remand for a new trial because the trial court

abused its discretion by overruling the defense’s objection to Detective

Tabares’ testimony that improperly bolstered the alleged victim’s credibility

and because the State failed to meet its burden to prove beyond a

reasonable doubt that the error did not contribute to the verdict.

                               BACKGROUND

      In 2021, the State charged Medrano-Chavez with one count of sexual

activity with a child by a person in familial or custodial authority in violation

of section 794.011(8)(b), Florida Statutes (2017) (Count I), and one count of

lewd and lascivious molestation on a child between 12 and 16 years of age

in violation of section 800.04(5)(c)2., Florida Statutes (2017) (Count II). The

alleged victim in both counts, K.M.C., is Medrano-Chavez’s biological

daughter. Medrano-Chavez’s trial defense was that he did not sexually

abuse K.M.C. and that she fabricated the alleged sexual abuse so that she

could apply for a “U-Visa” based on Medrano-Chavez’s alleged sexual

abuse.

      The State presented the testimony of Detective Humberto Tabares of



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the Miami-Dade Police Department Special Victims Unit. His testimony

reflected that in 2021, K.M.C., while in Maryland, called the Miami-Dade

Police Department to report that she had been sexually abused by Medrano-

Chavez in 2017 or 2018 in Miami-Dade County, while she was fourteen or

fifteen years old. Due to restrictions on travel as a result of COVID, he

contacted a police department in Maryland to interview K.M.C. During the

recorded interview, the Maryland detective presented a photograph of

Medrano-Chavez to K.M.C., and she identified Medrano-Chavez as the

perpetrator. The Maryland detective sent the video of the interview to

Detective Tabares.

      During Detective Tabares’ testimony, the prosecutor asked him what

he did next in his investigation after he received the video of the interview. In

response, he testified that he viewed the video, and then stated: “I saw

[K.M.C.’s] demeanor in the photograph [sic]. I you know, from my experience,

it was genuine.” The defense objected based on bolstering, and the trial court

overruled the objection. Detective Tabares then testified that he placed “a

message in the system for [Medrano-Chavez’s] apprehension,” and he was

arrested. The video was not shown to the jury.

      The State presented the testimony of K.M.C. and others. During

K.M.C.’s testimony, she testified, among other things, that Medrano-Chavez



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had sexually abused her in 2017 or 2018 in Miami-Dade County, while she

was fourteen or fifteen years old.

      The jury found Medrano-Chavez guilty as charged. Thereafter,

Medrano-Chavez filed a motion and supplemental motion for new trial, which

the trial court denied. The trial court sentenced Medrano-Chavez to life in

prison as to Count I and fifteen years in prison as to Count II. Medrano-

Chavez’s timely appeal followed.

                                 ANALYSIS

      Medrano-Chavez argues the trial court abused its discretion by

overruling the defense’s objection to Detective Tabares’ testimony that, in

light of his experience, K.M.C.’s demeanor in the video appeared “genuine.”1

We agree.

      A jury is “the sole arbiter of the credibility of witnesses.” Cochran v.

State, 411 So. 3d 1278, 1280 (Fla. 6th DCA 2025) (citing Barnes v. State, 93

So. 2d 863, 864 (Fla. 1957)). “Thus, it is an invasion of the jury’s exclusive

province for one witness to offer his personal view on the credibility of a

fellow witness.” Cochran, 411 So. 3d at 1280 (quoting Boatwright v. State,

452 So. 2d 666, 668 (Fla. 5th DCA 1984)); see also Seibert v. State, 923 So.


1
 “A trial court's ruling on the admissibility of evidence is reviewed under an
abuse of discretion standard.” Morris v. State, 233 So. 3d 438, 446 (Fla.
2018).

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2d 460, 472 (Fla. 2006) (“[A]llowing one witness to offer a personal view on

the credibility of a fellow witness is an invasion of the province of the jury to

determine a witness’s credibility.” (quoting Knowles v. State, 632 So. 2d 62,

65-66 (Fla. 1993))). “Moreover, ‘[i]t is especially harmful for a police witness

to give his opinion of a witnesses’ [sic] credibility because of the great weight

afforded an officer’s testimony.’” Seibert, 923 So. 2d at 472 (quoting Page v.

State, 733 So. 2d 1079, 1081 (Fla. 4th DCA 1999)); see also Tumblin v.

State, 29 So. 3d 1093, 1101 (Fla. 2010) (“Police officers, by virtue of their

positions, rightfully bring with their testimony an air of authority and

legitimacy. A jury is inclined to give great weight to their opinions . . . .”

(quoting Bowles v. State, 381 So. 2d 326, 328 (Fla. 5th DCA 1980))).

      The State challenges Medrano-Chavez’s argument on appeal that

Detective Tabares offered his personal view of K.M.C.’s credibility. In doing

so, the State asserts Detective Tabares was merely commenting as to the

steps he took in investigating K.M.C.’s report that Medrano-Chavez sexually

abused her. This argument does not completely reflect what occurred.

Although Detective Tabares was testifying as to the steps he took in his

investigation, his testimony also bolstered K.M.C’s credibility by stating that,

based on his experience, her demeanor was “genuine.” (emphasis added).

This bolstered K.M.C.’s credibility, and it was an abuse of discretion to



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overrule the defense’s objection in this regard.

      The State argues that even if the trial court abused its discretion by

overruling the defense’s objection to Detective Tabares’ testimony, the error

was harmless beyond a reasonable doubt. Based on our review of the

testimony and evidence presented at trial, we disagree.

      Here, K.M.C. was the only witness who testified that Medrano-Chavez

sexually abused her and there was no physical evidence to support K.M.C.’s

assertion as to the alleged sexual abuse. K.M.C.’s credibility played an

important role in the State’s prosecution of the case because it was K.M.C.’s

word versus Medrano-Chavez’s word. In addition, Medrano-Chavez

presented a defense that also placed K.M.C.’s credibility at issue—that

K.M.C. fabricated her accusations against Medrano-Chavez because she

was illegally in the United States and the allegations as to Medrano-Chavez

sexually assaulting her could assist her in obtaining a “U-Visa.” Finally, there

was testimony at trial that during a custody proceeding between Medrano-

Chavez and K.M.C.’s mother, the trial court appointed an investigator to

conduct an assessment of the home where Medrano-Chavez lived with

K.M.C. and two of her sisters and to make a recommendation to the trial

court. During the assessment, the investigator spoke to K.M.C., but she did

not disclose any sort of sexual abuse to the investigator even though



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Medrano-Chavez had already allegedly sexually abused K.M.C. at that time.2

Thus, based on the testimony and evidence presented at trial, the State

failed to meet its burden of establishing that the trial court’s improper

admission of Detective Tabares’ testimony bolstering K.M.C.’s credibility was

harmless beyond a reasonable doubt. See Cochran, 411 So. 3d at 1281

(“The harmless error test places the burden on the State to prove beyond a

reasonable doubt that the error did not contribute to the verdict.”).

Accordingly, we reverse Medrano-Chavez’s convictions and sentences and

remand for a new trial.

      Reversed and remanded.




2
 K.M.C. testified at trial that she did not tell the investigator that Medrano-
Chavez had sexually assaulted her because she was afraid of Medrano-
Chavez’s reaction.

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