GEORGE WILLIAMS, PETITIONER,
v.
MICHAEL W. MOORE, ETC., RESPONDENT
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George Williams petitioned the Florida Supreme Court for a writ of habeas corpus seeking overcrowding credits under Lynce v. Mathis and Gomez v. Singletary. The court held that individualized factual determinations regarding credit eligibility are better suited for circuit courts and directed that future such petitions be filed directly in circuit court rather than in the Supreme Court.
The court held that it will decline jurisdiction over habeas corpus petitions challenging overcrowding credit awards and will dismiss them without prejudice, directing inmates to file such claims directly in the appropriate circuit court, as the circuit courts are the proper forums for adjudicating the individualized factual issues involved.
[1] Inmates challenging the applicability of overcrowding credit charts to their individual situations retain the right to challenge such applicability.
[2] Petitions raising substantial issues of fact or individualized issues that do not require immediate resolution by the Florida Supreme Court should be dismissed without pr…
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“In-mates not parties to this action are generally bound by these appendixes but retain their right to challenge the applicability of the charts to their particular situations.”
Establishes that inmates retained individualized challenge rights while being bound by the Gomez charts generally
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Join FLexlaw to unlock all legal intelligenceWilliams sought overcrowding credits pursuant to federal and state law establishing that certain inmates should have received prison credits that were…
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PER CURIAM.
George Williams petitions this Court for a writ of habeas corpus. We have jurisdiction. Art. V, § 3(b)(9), Fla. Const. Williams seeks the award of overcrowding credits pursuant to the United States Supreme Court’s decision in Lynce v. Mathis, 519 U.S. 433, 117 S.Ct. 891, 137 L.Ed.2d 63 (1997), and this Court’s decision in Gomez v. Singletary, 733 So. 2d 499 (Fla.1998).
In Gomez, this Court addressed gain time in the context of prisoners who were never awarded certain types of credits but should have been awarded such credits. We held that the subsequent revisions in the prison overcrowding statutes which effectively made the petitioners ineligible to receive any credits constituted an ex-post-facto violation. Id. The decision also set forth a set of charts which provided for the number of credits to be awarded for each inmate according to that inmate’s “Offender Group.” The “Offender Groups” were a number of categories of inmates who had been arranged into groups by offense type and date. In a footnote to Gomez we noted that the amount of overcrowding credits to be awarded for each inmate in the respective groups would generally be determined by the charts set forth in the appendixes of the decision. See Gomez, 733 So. 2d at 508 n.
14. We indicated, however, that “[i]n-mates not parties to this action are generally bound by these appendixes but retain their right to challenge the applicability of the charts to their particular situations.” Id. (emphasis added).
Since the issuance of that opinion, we have received a large number of petitions from inmates in which the petitioners appear to be challenging the applicability of those charts. Whether an inmate has been properly classified as meeting the criteria for a particular “Offender Group” and whether the inmate had received no disciplinary reports for the pertinent month (so that the inmate was eligible for the actual receipt of the credits under the chart) are clearly individualized concerns which would in almost every case entail a number of factual determinations. In an even more recent decision from this Court we held that we will decline jurisdiction and transfer or dismiss without prejudice writ petitions which “raise substantial issues of fact or present individualized issues that do not require immediate resolution by this Court, or are not the type of case in which an opinion from this Court would provide important guiding principles for the other courts of this State.” Harvard v. Singletary, 733 So. 2d 1020, 1021-22 (Fla.1999).
The circuit courts of this State are fully capable of interpreting and applying the legal principles set forth in Gomez and our other recent overcrowding gaintime decisions. See, e.g., Meola v. Department of Corrections, 732 So. 2d 1029 (Fla.1998); State v. Lancaster, 731 So. 2d 1227 (Fla.1998), cert. denied, — U.S. -, 119 S.Ct. 1591, 143 L.Ed.2d 684 (1999); Thomas v. Singletary, 729 So. 2d 369 (Fla.1998), cert. denied, — U.S. -, 120 S.Ct. 200, 145 L.Ed.2d 169 (1999). Further, the circuit courts are the proper courts to adjudicate these issues of fact.
Therefore, we take this opportunity to explain that, as in the situation present in Harvard, in the future we will decline jurisdiction and dismiss without prejudice or transfer petitions seeking to challenge a denial or award of overcrowding credits.
Since the administrative burden of transferring these cases has become overwhelming, we direct that any inmates having such claims must file their petitions directly in the appropriate circuit court. From the date that this case becomes final, unless the petition shows upon its face an extraordinary circumstance for the transfer of the case to the appropriate circuit court, this Court will no longer transfer these claims but, rather, will dismiss them without prejudice.
Accordingly, we dismiss the instant petition without prejudice to Williams’ right to refile his petition in the appropriate circuit court.
It is so ordered.
HARDING, C.J., and SHAW, WELLS, ANSTEAD, PARIENTE, LEWIS and QUINCE, JJ., concur.
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McCONNELL v. Moore, 819 So. 2d 838 (Fla. 1st DCA 2002)…heir right to challenge the applicability of the charts to their particular situations. Gomez, 733 So. 2d at 508 n. 14. Mr. McConnell does not challenge the applicability of these charts to his particular situation. See generally Williams v. Moore, 752 So. 2d 574, 575 (Fla.2000) (stating that particular situations not resolved by the appendices included individualized concerns about whether an inmate was properly classified within one of1 the Gomez offender groups- and whether or not an inmate had received d…
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Crook v. Graceville CF Fdoc (N.D. Fla. 2025)…e could have 'proceed[ed] to the next step of the grievance process'— administrative appeal—after the expiration of 20 days."). Second, Crook did not file a petition for writ of mandamus or habeas corpus in the circuit court. See Williams v. Moore, 752 So.2d 574, 575 (Fla. 2000) (holding that "the [state] circuit courts are the proper place to adjudicate these issues of fact" concerning the application of gain time for prisoners.). In Pruitt v. Jones, 348 F.3d 1355, 1359 (11th Cir. 2003), the court held tha…
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Jenkins v. Dixon (N.D. Fla. 2024)…dicial review of agency action by the FDC involving gain time credits is available by petition for extraordinary relief (mandamus or habeas corpus) in the state circuit court. See Bush v. State, 945 So. 2d 1207, 1210 (Fla. 2006);³ Williams v. Moore, 752 So. 2d 574, 575 (Fla. 2000); Harvard v. Singletary, 733 So. 2d 1020, 1021-22 (Fla. 1999). Review of the circuit court’s decision is available by petition for writ of certiorari in the appropriate district court of appeal. See Sheley v. Fla. ³ “[I]f the prison…
Authorities Cited
- Lynce v. Mathis, 519 U.S. 433 (U.S. 1997)
- Gomez v. Singletary, 733 So. 2d 499 (Fla. 1998)
- Meola v. Dep't OF Corr., 732 So. 2d 1029 (Fla. 1998)
- Harvard v. Singletary, 733 So. 2d 1020 (Fla. 1999)
- State v. Lancaster, 731 So. 2d 1227 (Fla. 1998)
- Thomas v. Singletary, 729 So. 2d 369 (Fla. 1998)