JAMES STACEY CAUSEY, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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James Stacey Causey appealed the denial of his motion for postconviction relief, claiming his trial attorney was ineffective for failing to file a pretrial motion to sever his trial from codefendants. The court reversed and remanded because the trial court's order relied on insufficient documentary support and ambiguous evidence that did not allow proper appellate review.
The court reversed and remanded, holding that the documentary evidence attached by the trial court was insufficient for appellate review because it relied on an ambiguous motion for new trial filed by an attorney not identified as Causey's counsel, and the record needed to include the actual motion for severance filed on Causey's behalf.
[1] A trial court must attach sufficient documentation to support its order denying postconviction relief.
[2] A motion for new trial filed by one defendant's attorney on behalf of multiple defendants, which mentions a prior severance motion, may be too ambiguous to conclusively d…
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Join FLexlaw to unlock all legal intelligence“We conclude that the portion of the record which the trial court attached is not sufficient for this court to rule upon Causey's motion.”
Establishes the core holding that the trial court failed to provide adequate documentary support for its ruling.
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Join FLexlaw to unlock all legal intelligenceCausey was convicted of racketeering, attempted robbery, three counts of robbery, petit theft, and two counts of sexual battery. He filed a motion for…
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PER CURIAM.
James Stacey Causey appeals the denial of his motion for postconvietion relief. We reverse because the trial court failed to attach sufficient documents to support its order denying relief.
Causey was convicted of one count of racketeering, one count of attempted robbery, three counts of robbery, one count of petit theft, and two counts of sexual battery. He alleges in his motion for postconvietion relief that his trial attorney was ineffective in failing to file a pretrial motion to sever his trial from the codefendants. The trial court denied the motion for postconvietion relief, stating that the record reflected that a motion for severance and a motion for new trial raising the severance issue were denied. The trial court attached the motion for new trial to, support its ruling. The motion for new trial provided the following, in pertinent part:
COMES NOW, the defendant(s), JERE A. WALKER and the defendants GLEN WOODS, JAMES S. CAUSEY, by and through Patrick R. Sweeney, Attorney for JERE A. WALKER and file this their MOTION FOR NEW TRIAL, and in support thereof allege:
1. The Defendant(s) had filed a Motion for Severance of their trials and respective charges which was previously denied.
It is that language upon which the trial court relied in denying Causey’s motion.
We conclude that the portion of the record which the trial court attached is not sufficient for this court to rule upon Causey’s motion. Causey, in his motion for postconvietion relief, named two attorneys who represented him at various times from arraignment through the appeal of the case, and neither of them is Mr. Sweeney, the attorney who filed the motion for new trial. Further, we conclude that Mr. Sweeney’s motion for new trial, wherein he listed himself as only representing Walker but filed the motion on behalf of two other defendants and alleged that these two other defendants had filed motions for severance, is sufficiently ambiguous to direct the trial court to review the record and submit to this court Causey’s motion for severance filed in this case. We, therefore, reverse and remand this case to the trial court with directions to attach relevant portions of the record which address Causey’s motion for postconvietion relief.
Reversed and remanded.
PARKER, A.C.J., and PATTERSON and LAZZARA, JJ., concur.
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Redifer v. State, 641 So. 2d 192 (Fla. 2d DCA 1994)…ear facially sufficient; however, neither Redifer nor the court attaches portions of the record which substantiate or refute the arguments. We continue to require attachments to orders denying relief in rule 3.850 proceedings. See Causey v. State, 636 So. 2d 62 (Fla. 2d DCA 1994). Accordingly, we reverse the order of denial as it relates to the two issues described above and remand for further proceedings. If the trial court again denies the motion, it must attach those portions of the record that refute R…