WAYNE A. ADAMS
v.
RICKY D. DIXON, SECRETARY, FLORIDA DEPT. OF CORRECTIONS, AND C. MAIORANA, FACILITY ADMIN.
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A habeas corpus complaint must allege that the petitioner is unlawfully deprived of liberty or illegally detained, and courts lack authority to issue a writ of mandamus compelling particular medical treatment.
[1] A habeas corpus complaint must allege that the petitioner is currently detained in custody and show by affidavit or evidence probable cause to believe that he or she is d…
[2] Under the separation of powers doctrine, Florida courts lack authority to issue a writ of mandamus compelling the Department of Corrections to provide particular medical…
Previewing 2 of 2 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“In order to state a prima facie case for a writ of habeas corpus, the complaint must allege: 1) that the petitioner is currently detained in custody; and show 2) 'by affidavit or evidence probable cause to believe that he or she is detained without lawful authority.'”
Court's statement of the legal standard for habeas corpus relief, citing Quarles v. State and § 79.01, Fla. Stat.
Wayne A. Adams, an inmate in the custody of the Florida Department of Corrections, filed a habeas corpus petition requesting that the Department compe…
The full statement of facts, procedural history, and disposition for this case are member content.
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FIRST DISTRICT COURT OF APPEAL
STATE OF FLORIDA
_____________________________
No. 1D2024-1746 _____________________________
WAYNE A. ADAMS,
Appellant,
v.
RICKY D. DIXON, Secretary, Florida Dept. of Corrections, and
C. MAIORANA, Facility Admin.,
Appellees. _____________________________
On appeal from the Circuit Court for Santa Rosa County. Clifton A. Drake, Judge.
April 23, 2025
PER CURIAM.
Appellant challenges the dismissal, by the circuit court in Santa Rosa County, of his petition for a writ of habeas corpus on grounds that the complaint1 failed to state a prima facie case for the extraordinary writ. Appellant requested an order compelling the Department of Corrections to “take Petitioner to a vascular surgeon” for particular testing, evaluation, and treatment. The dismissal was “without prejudice” to Appellant’s “right to seek
In order to state a prima facie case for a writ of habeas corpus, the complaint must allege:1) that the petitioner is currently detained in custody; and show2) “by affidavit or evidence probable cause to believe that he or she is detained without lawful authority.” § 79.01, Fla. Stat. See also Smith v. Kearney, 802 So. 2d 387, 389 (Fla. 4th DCA 2001) (“To show a prima facie entitlement to habeas relief, the petitioner must show that he is
2 Appellant is in the custody of the Department serving the sentence entered in State v. Adams, Case No. 2020 CF 001143 (Fla. 5th Cir. Ct., Citrus Cnty.)
Appellant’s complaint did not allege that he was unlawfully deprived of his liberty or illegally detained by the Department. And the circuit court did not err by failing to construe Appellant’s complaint as seeking different relief, such as a writ of mandamus, to compel the Department to provide Appellant specific medical treatment by a specialized physician. This is because a court has no authority to issue a writ of mandamus compelling particular medical treatment. See Forney v. Crews, 112 So. 3d 741, 743 (Fla. 1st DCA 2013); see also Alqawasmeh v. State, 328 So. 3d 321, 323 (Fla. 2d DCA 2021) (under separation of the powers doctrine, Florida courts “wholly lack authority to direct the treatment and placement of prisoners serving sentences in the custody of the Florida Department of Corrections.”).
The order dismissing Appellant’s complaint for a writ of habeas corpus without prejudice to his right to seek “appropriate relief” is affirmed.
AFFIRMED.
OSTERHAUS, C.J., and ROBERTS and BILBREY, JJ., concur.
_____________________________
Not final until disposition of any timely and authorized motion under Fla. R. App. P. 9.330 or 9.331. _____________________________
Wayne A. Adams, pro se, Appellant.
Kelly R. Forren, Assistant General Counsel, Florida Department of Corrections, Tallahassee, for Appellees.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Glade Corr. Inst. v. Brownell, 719 So. 2d 1260 (Fla. 1st DCA 1998)
- Jackson v. State, 802 So. 2d 387 (Fla. 3d DCA 2001)
- Quarles v. State, 56 So. 3d 857 (Fla. 1st DCA 2011)
- T.S. v. State, 112 So. 3d 741 (Fla. 3d DCA 2013)