JEFFREY ALLEN MUEHLEMAN, PETITIONER,
v.
RICHARD L. DUGGER, ETC., RESPONDENT; JEFFREY ALLEN MUEHLEMAN, 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.
Jeffrey Allen Muehleman, a death row inmate, appeals the denial of his Rule 3.850 postconviction relief motion and seeks habeas corpus relief. The Florida Supreme Court holds that capital defendants are entitled to public records disclosure under chapter 119 and remands for the circuit court to allow Muehleman to amend his petition after receiving disclosed records from the sheriff.
The Florida Supreme Court held that capital postconviction defendants are entitled to chapter 119 public records disclosure. The court remanded the case to the circuit court, giving Muehleman sixty days from receipt of the records to amend his 3.850 petition to include facts or claims contained in the disclosed records, and reserved ruling on remaining issues until the circuit court reviews the amended petition.
[1] Capital post-conviction defendants are entitled to disclosure of public records under chapter 119, Florida Statutes.
[2] A circuit court errs in summarily denying a capital defendant's motion for post-conviction relief when the denial is predicated on the summary denial of a public records…
Previewing 2 of 4 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“It is well settled that capital post-conviction defendants are entitled to chapter 119 records disclosure.”
Establishes the fundamental right to public records disclosure for death row inmates pursuing postconviction relief
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceMuehleman was convicted of first-degree murder pursuant to guilty plea in 1983 and sentenced to death after a jury recommended death by a vote of ten …
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 Petition For Post Conviction Relief cases and more on FLexlaw
PER CURIAM.
Jeffrey Allen Muehleman, a prisoner under sentence of death, appeals the circuit court’s denial of his petition under Florida Rule of Criminal Procedure 3.850 and petitions this Court for a writ of habeas corpus. We have jurisdiction under article V, section 3(b)(1) of the Florida Constitution.
Muehleman was convicted of first-degree murder pursuant to a guilty plea in 1983. After a penalty proceeding, a jury recommended death by a vote of ten to two, and the trial judge followed the recommendation. On direct appeal, this Court upheld the conviction and sentence. Muehleman v. State, 503 So. 2d 310 (Fla.), cert. denied, 484 U.S. 882, 108 S.Ct. 39, 98 L.Ed.2d 170 (1987). Subsequently, posteonviction counsel made a public records request under chapter 119, Florida Statutes (1989), to the Pinellas County Sheriff for all records relating to the case. The sheriff did not fully comply with the request and Muehleman filed a motion to compel disclosure of public records pursuant to chapter 119. Muehleman also filed a motion for posteonviction relief.
The circuit court summarily denied all of the claims raised in Muehleman’s motion for posteonviction relief but granted the motion to compel disclosure of records under chapter 119. Further, the court granted Muehleman leave to file a new motion for posteonviction relief predicated on claims arising from the disclosure.
As his first issue on appeal, Muehleman argues that the circuit court erred in denying his motion under rule 3.850 while simultaneously granting his public records request. Muehleman claims that posteonviction counsel’s investigation of the case was frustrated by the refusal of the Pinellas County Sheriff to comply fully with Florida’s public records law. Presumably, counsel would have incorporated information contained in the sheriffs records into the rule 3.850 motion to support the claims raised therein and to support additional claims. In response, the State argues that the circuit court’s action, giving Muehleman leave to file a new motion for posteonviction relief if the disclosed records warrant it, was appropriate.
It is well settled that capital post-conviction defendants are entitled to chapter 119 records disclosure. Walton v. Dugger, 621 So. 2d 1357 (Fla.1993); State v. Kokal, 562 So. 2d 324 (Fla.1990); Provenzano v. Dugger, 561 So. 2d 541 (Fla.1990).
In Walton, this Court reviewed a circuit court order denying a capital defendant’s motion for posteonviction relief. 621 So. 2d at 1359. In his motion, the defendant raised a number of claims. Id. One of them involved the circuit court’s summary denial of a records disclosure issue under chapter 119. Id. This Court held that the summary denial was erroneous and ordered the circuit judge to hold an evidentiary hearing to determine whether the defendant was entitled to the records. Id. Regarding the remaining issues, we reserved ruling on them while the chapter 119 issue remained unresolved. Id. If the circuit court found that the defendant was, in fact, entitled to the records, we granted him thirty days from the rendition of that ruling in which to amend his motion for posteonviction relief to incorporate the additional claims or facts discovered as a result of the disclosure. Id.
We believe that the course we took in Walton is appropriate in the instant case. Accordingly, we relinquish jurisdiction of Muehleman’s case to the circuit court. Muehleman has sixty days from the date he receives the records to which he is entitled or from the date of this opinion, whichever is later, to amend his 3.850 petition to include any facts or claims contained in the sheriffs records. The circuit court should review the amended petition in light of the newly discovered information. In the interest of judicial economy, we reserve ruling on the remaining issues raised by Muehleman in his rule 3.850 appeal and his habeas petition until the circuit court rules on the amended motion.
It is so ordered.
BARKETT, C.J., and OVERTON, McDonald, shaw, grimes, kogan and HARDING, JJ., concur.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By
-
Anderson v. State, 627 So. 2d 1170 (Fla. 1993)…ublic record requests. This Court has made clear that a prisoner whose conviction and sentence of death has become final on direct review is generally entitled to criminal investigative public records as provided in chapter 119. Muehleman v. Dugger, 623 So. 2d 480 (Fla.1993) (sheriff's records); Walton v. Dugger, 621 So. 2d 1357 (Fla.1993) (sheriffs and state attorney’s files); Mendyk v. State, 592 So. 2d 1076, 1081 (Fla.1992) (records of sheriffs offices and the Florida Parole Commission), receded from on ot…
-
Moore v. State, 820 So. 2d 199 (Fla. 2002)…ion relief upon the receipt of public records to include and new or additional claims in light of information obtained from the furnished documents. See Ventura v. State, 673 So. 2d 479, 481 (Fla.1996); Reed, 640 So. 2d at 1098; Muehleman v. Dugger, 623 So. 2d 480, 481 (Fla.1993). However, a second or successive motion for postconviction relief can be denied on the ground that it is an abuse of process if there is no reason for failing to raise the issues in the previous motion. See Pope v. State, 702 So. 2d…
-
Buenoano v. State, 708 So. 2d 941 (Fla. 1998)…ld amend initial rule 3.850 motions after all requested public records were furnished. See Ventura v. State, 673 So. 2d 479 (Fla.1996); Walton v. Dugger, 634 So. 2d 1059 (Fla.1993); Anderson v. State, 627 So. 2d 1170 (Fla.1993); Muehleman v. Dugger, 623 So. 2d 480 (Fla.1993); Provenzano v. Dugger, 561 So. 2d 541 (Fla.1990). However, each of the cases in which the Court remanded to allow for an amended rule 3.850 motion involved an initial timely rule 3.850 motion. Here, we are presented with Buenoano’s third…
Previewing 3 of 4 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Provenzano v. Dugger, 561 So. 2d 541 (Fla. 1990)
- State v. Kokal, 562 So. 2d 324 (Fla. 1990)
- Muehleman v. State, 503 So. 2d 310 (Fla. 1987)
- Muehleman v. Florida, 484 U.S. 882 (U.S. 1987)