BENITO SANTIAGO
v.
STATE OF FLORIDA

Fla. 3d DCA | 2026-01-21
No. 2026-0010
2026 FL 653 Florida District Court of Appeal, Third District (2026)

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Synopsis

Benito Santiago sought a writ of habeas corpus to challenge his 2012 first-degree murder conviction, claiming manifest injustice. The Florida District Court of Appeal, Third District, denied the petition, finding that Santiago's case did not fall within the narrow exception for habeas corpus relief based on manifest injustice.


Holding

The court held that Santiago's case does not fall within the narrow exception for habeas corpus relief based on manifest injustice, and therefore the petition for habeas corpus was denied.


Headnotes

[1] A writ of habeas corpus may be used to correct a manifest injustice.

[2] The mere incantation of the words 'manifest injustice' is insufficient to warrant relief via habeas corpus.

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Key Quotes

“That writ is enshrined in our Constitution to be used as a means to correct manifest injustices and its availability for use when all other remedies have been exhausted has served our society well over many centuries.”

Establishes the constitutional purpose and availability of habeas corpus as a remedy for manifest injustice when other remedies are exhausted

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Facts & Procedural History

Benito Santiago was convicted in 2012 of two counts of first-degree murder. He subsequently sought habeas corpus relief, invoking the manifest injusti…

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Per_curiam
Per Curiam

Third District Court of Appeal State of Florida Opinion filed January 21, 2026. Not final until disposition of timely filed motion for rehearing. No. 3D26-0010 Lower Tribunal No. F06-5240 Benito Santiago, Petitioner, VS. State of Florida, Respondent. A Case of Original Jurisdiction – Habeas Corpus. Benito Santiago, in proper person. James Uthmeier, Attorney General, for respondent. Before LOGUE, LINDSEY, and GOODEN, JJ. PER CURIAM. Claiming manifest injustice, Petitioner Benito Santiago seeks a writ of habeas corpus attacking his 2012 conviction for two counts of first degree

murder. See Baker v. State, 878 So. 2d 1236, 1246 (Fla. 2004) (Anstead, C.J, specially concurring) (“That writ is enshrined in our Constitution to be used as a means to correct manifest injustices and its availability for use when all other remedies have been exhausted has served our society well over many centuries. This Court will, of course, remain alert to claims of manifest injustice, as will all Florida courts.”); Lightner v. State, 306 So. 3d 1019, 1021 (Fla. 3d DCA 2020) (“Under Florida law, appellate courts have the authority to correct a manifest injustice by way of habeas corpus."). "Nevertheless, this exception only applies to a narrow category of cases." Leach v. State, 406 So. 3d 272 (Fla. 3d DCA 2025).

Yet the “mere incantation of the words 'manifest injustice' does not make it so.” Beiro v. State, 289 So. 3d 511, 511 (Fla. 3d DCA 2019).

Finding this case does not fall within this narrow exception and no manifest injustice occurred, we deny the petition. Petition denied. 2


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