FRANCIS JEANTILUS, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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In this postconviction relief case, the Florida Fourth District Court of Appeal affirms the trial court's denial of Jeantilus's Rule 3.850 motion challenging the voluntariness of his confession. The court had previously remanded for an evidentiary hearing due to a gap in the trial transcript where the confession issue was discussed off the record; the trial court's factual findings at that hearing, supported by competent substantial evidence, are now upheld on appeal.
The trial court's denial of the Rule 3.850 motion for postconviction relief is affirmed because the trial court's factual findings are supported by competent substantial evidence. The omission from the transcript was inadvertent, defense counsel's decision not to file a suppression motion was reasonable and strategically sound, and appellant's credibility was properly questioned.
[1] A trial court's factual findings following an evidentiary hearing on a motion for postconviction relief are entitled to deference and will not be disturbed if supported b…
[2] Competent substantial evidence is defined as evidence that establishes a substantial basis of fact from which the fact at issue can be reasonably inferred.
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“As long as the trial court's findings are supported by competent substantial evidence, this Court will not 'substitute its judgment for that of the trial court on questions of fact, likewise of the credibility of the witnesses as well as the weight to be given to the evidence by the trial court.'”
Establishes the deferential standard of review for Rule 3.850 denials after an evidentiary hearing
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceDuring Jeantilus's trial, a discussion regarding his confession occurred while the court reporter was absent retrieving a recording disk, creating a g…
The full statement of facts, procedural history, and disposition for this case are member content.
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WARNER, J.
In Jeantilus v. State, 853 So. 2d 1099 (Fla. 4th DCA 2003), we reversed the summary denial of one issue raised in appellant’s motion for postconviction relief because of the insufficiency of the record. Specifically, appellant had claimed that his confession was not voluntary, but when the issue came up at trial, the discussion was not recorded. We remanded for an evidentiary hearing on the issue. Based upon the trial court’s detailed findings, we affirm the court’s denial of the motion for postconviction relief.
The trial court found that the omission of the discussion was inadvertent and occurred when the court reporter was momentarily absent from the courtroom to retrieve an additional recording disk. The gap in the transcription of the proceedings was only a few minutes.
During the unrecorded discussion, defense counsel told the judge that he would not be asking the court to hear a motion to suppress the confession, having already determined that he had no grounds to request suppression. Defense counsel also noted that appellant had agreed with him and explained how he intended to attack the confession at trial.
Appellant also testified at the hearing, as did several detectives. Appellant claimed the he was subtly coerced into his confession and that he never agreed with his attorney’s strategy not to file a motion to suppress. The court did not find appellant to be a credible witness. Moreover, the court found that defense counsel’s strategy was reasonable.
The standard of review following denial of a rule 3.850 claim after an evidentiary hearing requires deference to the trial court’s factual findings. “As long as the trial court’s findings are supported by competent substantial evidence, this Court will not ‘substitute its judgment for that of the trial court on questions of fact, likewise of the credibility of the witnesses as well as the weight to be given to the evidence by the trial court.’ ” McLin v. State, 827 So. 2d 948, 954 n. 4 (Fla.2002) (quoting Blanco v. State, 702 So. 2d 1250, 1252 (Fla.1997)). Competent substantial evidence is “such evidence as will establish a substantial basis of fact from which the fact at issue can be reasonably inferred.” De Groot v. Sheffield, 95 So. 2d 912, 916 (Fla.1957).
Further, “[sjtrategic decisions do not constitute ineffective assistance of counsel if alternative courses have been considered and rejected and counsel’s decision was reasonable under the norms of professional conduct.” Brown v. State, 894 So. 2d 137, 147 (Fla.2004).
Because there was competent substantial evidence to support the trial court’s findings, we affirm the order denying relief.
STONE and POLEN, JJ., concur.
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Hedrick v. State, 6 So. 3d 688 (Fla. 4th DCA 2009)…decision credible. A trial court’s factual determinations following an evidentiary hearing on a post-conviction motion are entitled to deference and should not be disturbed if they are supported by competent substantial evidence. Jeantilus v. State, 944 So. 2d 500 (Fla. 4th DCA 2006). The second aspect of this point is the court’s denial of the defendant’s claim that counsel should have objected to the co-defendants appearing at trial in shackles and prison garb. The co-defendants were brought into the court…
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Sanchez v. State, 174 So. 3d 439 (Fla. 4th DCA 2015)…dence, [the District Court] will not ‘substitute its judgment for that of the trial court on questions of fact, likewise of the credibility of the witnesses as well as the weight to be given to the evidence by the trial court.’ ” Jeantilus v. State, 944 So. 2d 500, 501 (Fla. 4th DCA 2006). Although Sanchez claims that he owned the personal property found on his person, the trial court specifically found his testimony not credible. Thus, he failed to prove the property was exclusively his [*443] own. The stat…
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Brancaccio v. State, 27 So. 3d 739 (Fla. 4th DCA 2010)…an acquittal on retrial.” Jones, 591 So. 2d at 915 (emphasis in original). The standard of review following denial of a rule 3.850 claim after an eviden-tiary hearing requires deference to the trial court’s factual findings. See Jeantilus v. State, 944 So. 2d 500, 501 (Fla. 4th DCA 2006). The legal conclusions of the trial court are reviewed de novo. Demps v. State, 761 So. 2d 302, 306 (Fla.2000). Absent an abuse of discretion, a trial court’s decision on a motion claiming newly discovered evidence will not…
Previewing 3 of 5 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- de Groot v. Sheffield, 95 So. 2d 912 (Fla. 1957)
- McLIN v. State, 827 So. 2d 948 (Fla. 2002)
- Blanco v. State, 702 So. 2d 1250 (Fla. 1997)
- Brown v. State, 894 So. 2d 137 (Fla. 2004)
- Jeantilus v. State, 853 So. 2d 1099 (Fla. 4th DCA 2003)