MARTINEZ WATTS
v.
THE STATE OF FLORIDA
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Martinez Watts appealed the denial of his habeas corpus petition challenging the validity of his 2013 arrest for burglary of a dwelling, to which he pleaded guilty in 2014. The court affirmed the denial, holding that habeas corpus cannot be used as a substitute for postconviction relief motions or to relitigate issues previously raised.
Habeas corpus may not be used as a substitute for an appropriate motion seeking postconviction relief, nor can it be used to seek a second appeal or relitigate issues that could have been or were raised in a Rule 3.850 motion. The trial court properly denied Watts' habeas corpus petition.
[1] Habeas corpus cannot be used as a substitute for postconviction relief procedures under rule 3.850 or as a means to relitigate issues that could have been or were raised…
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Join FLexlaw to unlock all legal intelligence“habeas corpus may not be used as a substitute for an appropriate motion seeking postconviction relief, . . . [n]or can habeas corpus be used as a means to seek a second appeal or to litigate issues that could have been or were raised in a motion under rule 3.850”
Court citation to Baker v. State establishing well-established principles regarding limitations on habeas corpus petitions
Watts was arrested in November 2013 for burglary of a dwelling and subsequently pleaded guilty in April 2014 after seven original charges were reduced…
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Opinion filed November 24, 2021. Not final until disposition of timely filed motion for rehearing.
________________ No. 3D21-886 Lower Tribunal No. 13-287-A-P ________________
Martinez Watts,
Appellant,
vs.
The State of Florida,
Appellee.
An Appeal from the Circuit Court for Monroe County, Luis Garcia, Judge. Martinez Watts, in proper person. Ashley Moody, Attorney General, for appellee. Before EMAS, GORDO and LOBREE, JJ. EMAS, J.
Martinez Watts appeals from the trial court's order denying his July 2020 petition for writ of habeas corpus, by which Watts sought to challenge the validity of his November 2013 arrest, which resulted in a charge of burglary of a dwelling, to which he pleaded guilty in April 2014.1 We note that the trial court previously denied a 2016 motion for postconviction relief in which Watts raised the very same issue but couched it as a claim of ineffective assistance of counsel in failing to file a motion to suppress evidence resulting from an invalid arrest. We affirmed the trial court’s order denying that 2016 motion, see Watts v. State, 206 So. 3d 715 (Fla. 3d DCA 2016),2 and we affirm the instant order as well. See Baker v. State, 878 So. 2d 1236, 1241 (Fla. 2004) (reaffirming the well-established principles that “habeas corpus may not be used as a substitute for an appropriate motion seeking postconviction relief, . . . [n]or can habeas corpus be used as a means to seek a second appeal or to litigate issues that could have been or were raised in a motion under rule 3.850”) (citations omitted);
Beiro v. State, 289 So. 3d 511, 511 (Fla. 3d DCA 2019) (noting: “The mere incantation of the words ‘manifest injustice’ does not make it so.”) Affirmed.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Baker v. State, 878 So. 2d 1236 (Fla. 2004)
- Maykel Beiro v. State, 289 So. 3d 511 (Fla. 3d DCA 2020)