MICHAEL ANTHONY WOODS
v.
STATE OF FLORIDA
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When a pro se incarcerated defendant timely files an amended postconviction motion under the prisoner mailbox rule within the court-ordered deadline, the trial court must accept and adjudicate the motion rather than deny it as untimely.
[1] A pro se incarcerated defendant's postconviction motion is deemed timely filed under the prisoner mailbox rule when mailed within a court-ordered deadline, regardless of…
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Join FLexlaw to unlock all legal intelligence“Under the mailbox rule, a petition or notice of appeal filed by a pro se inmate is deemed filed at the moment in time when the inmate loses control over the document by entrusting its further delivery or processing to agents of the state.”
Explaining the prisoner mailbox rule and when a filing is deemed complete for pro se incarcerated litigants.
Michael Anthony Woods, an incarcerated pro se defendant, received an October 24, 2025 order finding his postconviction motion facially insufficient an…
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Third District Court of Appeal
State of Florida
Opinion filed October 14, 2026.
Not final until disposition of timely filed motion for rehearing.
No. 3D26-0286 Lower Tribunal No. F17-9835
Michael Anthony Woods, 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, Milton Hirsch, Judge.
Michael Anthony Woods, in proper person.
James Uthmeier, Attorney General, and Daniel Colmenares and Jason Michael Ross, Assistant Attorneys General, for appellee.
Before SCALES, C.J., and LOGUE and LOBREE, JJ.
PER CURIAM.
On the State's Confession of Error
The record reflects that, in an October 24, 2025 order, the postconviction court found appellant Michael Anthony Woods's postconviction motion facially insufficient and denied the motion without prejudice to Woods filing an amended motion within sixty days. Woods, who is incarcerated, filed his amended postconviction motion fifty-four days later, on December 17, 2025, under the prisoner mailbox rule. See Haag v. State, 591 So. 2d 614, 617 (Fla. 1992) (“Under the mailbox rule, a petition or notice of appeal filed by a pro se inmate is deemed filed at the moment in time when the inmate loses control over the document by entrusting its further delivery or processing to agents of the state. Usually, this point occurs when the inmate places the document in the hands of prison officials.”). It appears that Woods's amended motion was not received by the trial court until January 5, 2026.
Because Woods's amended postconviction motion was timely filed, the trial court's final orders of December 30, 2025, and January 20, 2026 (the "Orders”), denying Woods's respective motions must be reversed, and the case be remanded with instructions for the postconviction court to adjudicate Woods's amended postconviction motion. See Simmons v. State, 293 So. 3d 604, 606 (Fla. 1st DCA 2020) (“Because the postconviction court had unrebutted evidence that the appellant timely filed his motion for postconviction relief, it erred by failing to accept the filing as timely filed. Accordingly, we reverse and remand for further proceedings.”); Loray v. State, 80 So. 3d 428, 429 (Fla. 4th DCA 2012) (“Based on application of this authority, and the State's response agreeing that the matter should be remanded to the trial court, we reverse and remand for further consideration of this motion for post-conviction relief.”).
Based on the State's commendable confession of error, we reverse the Orders and remand with instructions.
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