MARK D. HADLEY
v.
STATE OF FLORIDA
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A technical deficiency in an arrest affidavit does not deprive the circuit court of jurisdiction in a criminal case.
[1] Technical deficiencies in an arrest affidavit do not deprive a circuit court of subject matter jurisdiction in a criminal case.
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Court's statement of applicable law from Smith v. State
Mark D. Hadley appealed from a circuit court decision in Miami-Dade County. The appeal involved a challenge to the trial court's jurisdiction based on…
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Third District Court of Appeal
State of Florida
Opinion filed July 30, 2026.
Not final until disposition of timely filed motion for rehearing.
No. 3D26-0582
Lower Tribunal No. F94-38195A
Mark D. Hadley,
Appellant,
vs.
State of Florida,
Appellee.
An Appeal under Florida Rule of Appellate Procedure 9.141(b)(2) from the Circuit Court for Miami-Dade County, Laura Anne Stuzin, Judge.
Mark D. Hadley, in proper person.
James Uthmeier, Attorney General, and Richard L. Polin, Chief Assistant Attorney General, for appellee.
Before MILLER, LOBREE, and BOKOR, JJ.
PER CURIAM.
Affirmed. See Smith v. State, 82 So. 3d 823, 824 (Fla. 4th DCA 2011) ("A technical deficiency in an arrest affidavit does not deprive the circuit court of jurisdiction in a criminal case." (citing State v. Faidy, 919 So. 2d 582, 583 (Fla. 5th DCA 2006); State v. Ballone, 422 So. 2d 900, 901 (Fla. 2d DCA 1982))); Wardell v. State, 944 So. 2d 1089, 1091 (Fla. 5th DCA 2006) (“[T]he manner by which a criminal defendant is brought before a court, even if improper, does not divest a court of subject matter jurisdiction.").
2
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- State v. Ballone, 422 So. 2d 900 (Fla. 2d DCA 1982)
- Abel Smith v. State, 82 So. 3d 823 (Fla. 4th DCA 2011)
- Wardell v. State, 944 So. 2d 1089 (Fla. 5th DCA 2006)