FREDDY D. WADDELL
v.
STATE

Fla. 5th DCA | 2018-05-28
No. 5D18-694
Florida District Court of Appeal, Fifth District (2018)

AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.


Holding

A defendant filing a legally insufficient Florida Rule of Criminal Procedure 3.850 postconviction motion must be given at least one opportunity to amend the deficient claim unless the defect is incurable.


Headnotes

[1] A trial court must provide a defendant filing a facially insufficient Florida Rule of Criminal Procedure 3.850 postconviction motion at least one opportunity to amend and…

Previewing 1 of 1 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.

Join FLexlaw to unlock all legal intelligence

Key Quotes

“A defendant who files a legally insufficient rule 3.850 motion should be given at least one opportunity to correct the deficiency, unless it is apparent that the defect cannot be corrected.”

Court's reasoning supporting reversal and remand of Ground Three, citing Parsons v. State.

Facts & Procedural History

Freddy D. Waddell appealed the summary denial of his postconviction relief motion filed under Florida Rule of Criminal Procedure 3.850, which containe…

The full statement of facts, procedural history, and disposition for this case are member content.

Join FLexlaw to unlock all legal intelligence

© FLexlaw, Inc. — AI-generated enrichments are proprietary. All rights reserved.


Opinion of the Court

PER CURIAM. Freddy D. Waddell appeals the summary denial of his motion for postconviction relief filed pursuant to Florida Rule of Criminal Procedure 3.850. We affirm as to Grounds

One, Two, and Four of Waddell’s motion without further discussion. In Ground Three,

Waddell contends that his trial counsel was ineffective for failing to object to a statement made by the trial court regarding Waddell’s maximum possible sentence that allegedly showed prejudice. Because this claim was facially insufficient, Waddell should have the opportunity to amend it. See Parsons v. State, 981 So. 2d 1249, 1250 (Fla. 5th DCA

2008) (“[A] defendant who files a legally insufficient rule 3.850 motion should be given at least one opportunity to correct the deficiency, unless it is apparent that the defect cannot be corrected.”). We therefore reverse and remand on Ground Three for the postconviction court to provide Waddell the opportunity to amend the claim in good faith.

AFFIRMED in part; REVERSED in part; REMANDED. COHEN, C.J., SAWAYA and BERGER, JJ., concur.


Cases With Similar Vibessemantic neighbors from the corpus


Citator

Authorities Cited

Full citator, related cases, and AI research tools

Open in FLexlaw