STEVEN GAMBLE
v.
STATE OF FLORIDA

Fla. 3d DCA | 2026-03-11
No. 2025-2511
Florida District Court of Appeal, Third District (2026)

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Holding

Florida Rule 1.540, which applies only to civil causes, does not apply to collateral claims associated with a criminal conviction.


Key Quotes

“By its own terms, rule 1.540 applies only to civil causes, not to collateral claims associated with a criminal conviction.”

Steinhorst v. State, 636 So. 2d 498, 500 (Fla. 1994)

Facts & Procedural History

Gamble filed a motion in a criminal matter under Florida Rule 1.540, which is applicable only to civil cases. The trial court rejected the motion as p…

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Opinion of the Court

PER CURIAM. Affirmed. See Steinhorst v. State, 636 So. 2d 498, 500 (Fla. 1994) (“By its own terms, rule 1.540 applies only to civil causes, not to collateral claims associated with a criminal conviction.”); Bryant v. State, 971 So. 2d 818, 819 (Fla. 3d DCA 2007) (“The defendant was incorrect to file a motion under Rule 1.540 . . . When such a motion is filed, it is to be treated as if it had been filed under the correct postconviction rule.").


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