CHARITY NOELLE WOOD
v.
STATE OF FLORIDA
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.
Charity Noelle Wood appeals the trial court's order striking her habeas corpus petition filed while committed to a mental health facility after being found incompetent to proceed. The appellate court reversed, holding that Florida statute 916.107(9)(a) grants forensic clients the explicit right to petition for habeas corpus in the committing court, regardless of whether they are represented by counsel.
A forensic client has the explicit statutory right under Florida Statutes section 916.107(9)(a) to petition for habeas corpus in the committing court to challenge the cause and legality of her detention, regardless of counsel representation or the location of the facility. The committing court has jurisdiction to entertain such petitions.
[1] A forensic client committed to a mental health treatment facility pursuant to section 916.13, Florida Statutes, has a statutory right to petition the committing court for…
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“[QUOTE REDACTED — failed verbatim audit (paraphrase, not verbatim). See original_text for the text as originally displayed.]”
Establishes the statutory right of forensic clients to petition for habeas corpus in the committing court
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceMs. Wood was charged with a third-degree felony in Pinellas County in May 2022. On March 16, 2023, the trial court found her incompetent to proceed an…
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.
Explore caselaw by topic → Browse Competency To Proceed cases and more on FLexlaw
DISTRICT COURT OF APPEAL OF FLORIDA
SECOND DISTRICT
CHARITY NOELLE WOOD,
Appellant,
v.
STATE OF FLORIDA,
Appellee.
No. 2D23-1927
April 3, 2024
Appeal from the Circuit Court for Pinellas County; Pat Siracusa, Judge. VILLANTI, Judge.
Charity Noelle Wood appeals from an order striking her petition for writ of habeas corpus. For the reasons explained below, we reverse. Ms. Wood was charged with a third-degree felony alleged to have been committed in Pinellas County, Florida, in May 2022. On March 16, 2023, the trial court found her incompetent to proceed and committed her to the Department of Children and Families (Department) for placement in a mental health treatment facility pursuant to section 916.13, Florida Statutes (2022). Ms. Wood was subsequently admitted to the Florida State Hospital in Chattahoochee, Florida. On August 4, 2023, Ms. Wood filed a petition for writ of habeas corpus in the Pinellas County Circuit Court. The trial court struck the petition for two reasons. First, the court ruled that because Ms. Wood was represented by counsel, her pro se pleading was a nullity. (Citing Murray v. State,1 So. 3d 407, 408 (Fla. 2d DCA 2009) ("A defendant does not have the right to file pro se motions while also represented by counsel, and such motions should be treated as nullities unless they unequivocally seek to discharge counsel.").) Second, the court ruled that it did not have the authority to rule on the petition because Ms. Wood's place of confinement was not within the trial court's territorial jurisdiction. (Citing Valdez-Garcia v. State, 965 So. 2d 318, 322 (Fla. 2d DCA 2007) ([H]olding that the sentencing court did not have jurisdiction to consider a petition for habeas corpus when the prisoner was incarcerated in a different county).) The trial court also found that Ms. Wood's commitment to the mental health treatment facility was authorized by its March 16, 2023, order "and is therefore lawful." Both of the trial court's reasons for striking Ms. Wood's petition are incorrect.1 Section 916.107(9)(a) states, in pertinent part: (9) HABEAS CORPUS. (a) At any time, and without notice, a forensic client detained by a facility, or a relative, friend, guardian, representative, or attorney on behalf of such client, may petition for a writ of habeas corpus to question the cause and legality of
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Valdez-Garcia v. State, 965 So. 2d 318 (Fla. 2d DCA 2007)
- Murray v. State, 1 So. 3d 407 (Fla. 2d DCA 2009)
- Franklin v. Kearney, 814 So. 2d 462 (Fla. 4th DCA 2001)
- Errol Lewis v. James, 88 So. 3d 381 (Fla. 1st DCA 2012)