Vizzi v. State

Vizzi, an assistant public defender, was defending his client charged with sexual battery, kidnapping, and false imprisonment and referred to the victim as “a woman who’s trash, gutter filth.” After being admonished by the court, Vizzi proceeded to call the victim “a whore, a two-bit whore.” The prosecutor petitioned the court to instruct Vizzi not to call the victim a prostitute again and the trial court ruled, based on Florida’s Rape Victim Shield Statutes, that Vizzi was not permitted to attack the character of the victim by delving into her prior sexual behavior (other than prior sexual activity that the victim had with the defendant) or by calling the victim a prostitute, whore, or words of similar meaning. Vizzi later called the victim an “exhibitionist” and questioned the victim with respect to her “perform[ing] tricks with customers.” The trial court held Vizzi in contempt for violating its prior order and sentenced him to 5 days of jail time. The appellate court upheld the contempt order based on Vizzi’s failure to comply with the trial court’s ruling.