ERIC A. RANDALL, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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.
Eric Randall appealed the summary denial of his post-conviction relief motion, claiming the trial judge failed to establish a factual basis for his plea and that the prosecution failed to disclose evidence favorable to him. The court reversed, finding the record did not conclusively show Randall was entitled to no relief on either claim.
The court reversed the summary denial and remanded for an evidentiary hearing or a new order with conclusive evidence, because the record did not show that Randall was entitled to no relief on either of his two claims.
[1] A trial court's summary denial of a motion for postconviction relief must be reversed when the record fails to conclusively show that the movant is entitled to no relief…
[2] A conviction obtained by the prosecution's failure to disclose evidence favorable to the defendant violates due process under Brady v. …
Previewing 2 of 5 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“the record fails to conclusively show that Randall is entitled to no relief under two of his claims”
The court's basis for reversing the summary denial and requiring further proceedings
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceRandall pleaded nolo contendere to aggravated battery on March 7, 1990. According to his motion, the alleged victim had filed an affidavit with the st…
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 Brady Violation cases and more on FLexlaw
PER CURIAM.
Eric A. Randall appeals from the summary denial of his motion for postconviction relief pursuant to Florida Rule of Criminal Procedure 3.850. Because the record fails to conclusively show that Randall is entitled to no relief under two of his claims, we reverse. See Fla.R.App.P. 9.140(g).
Randall claims that he was prejudiced by the trial judge’s failure to establish, in the record, the necessary factual basis for the plea, as required by Florida Rule of Criminal Procedure 3.172. See Williams v. State, 316 So. 2d 267 (Fla.1975). The record before us does not show that the trial judge complied with this requirement. It also fails to show an absence of prejudice or manifest injustice as a result of any noncompliance with the rule. Williams, 316 So. 2d at 275.
Randall also claims that his conviction was obtained by the unconstitutional failure of the prosecution to disclose evidence favorable to him. See Brady v. Ma ryland, 373 U.S. 83, 83 S.Ct. 1194, 10 L.Ed.2d 215 (1963); Mendyk v. State, 592 So. 2d 1076, 1079 (Fla.1992). According to the allegations in Randall’s motion, he pled nolo contendere to aggravated battery on March 7, 1990, but, unbeknownst to him, the alleged victim had gone to the office of the state attorney on February 22, 1990, and filed an affidavit stating her desire not to prosecute and requesting that the charges be dismissed. Randall also alleges that if the state attorney’s office had informed him of this, he would not have pled to the charge. It is reasonable to assume that knowledge of the alleged victim’s actions would have been useful to Randall at trial. Clearly, this would have provided useful impeachment evidence. Accordingly, the allegations of the motion state a colorable claim under Brady that is not refuted by the record before us.
We reverse the order summarily denying Randall’s claims, and we remand this cause to the trial court. The trial court is directed to either conduct an evidentiary hearing or attach to its new order that portion of the files and records of this case which conclusively shows that Randall is entitled to no relief under the claims discussed above.
BOOTH, SMITH and ALLEN, JJ., concur.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By
-
Taylor v. State, 848 So. 2d 410 (Fla. 1st DCA 2003)…for impeachment purposes, (2) the state suppressed the evidence, either willfully or inadvertently, and (3) the appellant was prejudiced by the suppression of the evidence. State v. Huggins, 788 So. 2d 238, 242 (Fla.2001); see also Randall v. State, 604 So. 2d 36 (Fla. 1st DCA 1992). In the context of a trial, an appellant must allege that the suppression of evidence undermines the confidence in the jury’s verdict. Huggins, 788 So. 2d at 243-244. In the context of a plea, an appellant must allege that he wou…
Authorities Cited
- Brady v. Maryland, 373 U.S. 83 (U.S. 1963)
- Williams v. State, 316 So. 2d 267 (Fla. 1975)
- State v. Cerrito, 592 So. 2d 1076 (Fla. 1991)