STACY LEE WATTS, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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Stacy Lee Watts appeals the denial of his postconviction relief motion under Florida Rule of Criminal Procedure 3.850, claiming ineffective assistance of counsel. The Second District Court of Appeal affirmed the denial of claims one and three but reversed and remanded claim two because the postconviction court failed to address Watts's allegation that trial counsel was ineffective for failing to investigate his mental health and seek a competency determination.
The court affirmed the denial of claims one and three as procedurally barred because they allege trial court error that should have been raised on direct appeal. However, the court reversed and remanded claim two because the postconviction court failed to address the ineffective assistance of counsel allegation, which is cognizable in a 3.850 motion and was not conclusively refuted by the record.
[1] A claim that trial counsel was ineffective for failing to investigate a defendant's mental health and seek a competency determination is cognizable in a motion for post-c…
[2] A post-conviction court must address all claims raised in an amended motion for post-conviction relief.
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“[T]he narrow argument that counsel was ineffective for failing to raise a defendant's competency is cognizable in a rule 3.850 motion.”
Establishes that ineffective assistance claims regarding competency are properly raised in postconviction motions and distinguishes them from trial court error claims.
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Join FLexlaw to unlock all legal intelligenceWatts was convicted of carjacking, aggravated fleeing to elude, driving with a suspended license, and possession of paraphernalia. He was sentenced as…
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Stacy Lee Watts appeals the order summarily denying his motion for postcon-viction relief filed pursuant to Florida Rule of Criminal Procedure 3.850. We affirm without comment the denial of Watts’s original 3.850 motion. We also affirm the denial of claims one and three of Watts’s amended 3.850 motion.1 However, we reverse and remand on claim two of Watts’s amended 3.850 motion because the post-conviction court failed to address it.
Watts was originally convicted of carjacking, aggravated fleeing to elude, driving with a suspended license, and possession of paraphernalia. He was sentenced as a habitual offender to life in prison for carjacking, a concurrent thirty years in prison for aggravated fleeing to elude, one year in county jail for driving with a suspended license, and time served for possession of paraphernalia.
In claim two of Watts’s amended 3.850 motion, he alleged that trial counsel was ineffective for failing to investigate Watts’s mental health and for failing to seek a competency determination. Such a claim is cognizable in a rule 3.850 motion, see Demarco v. State, 31 So.3d 975, 976 (Fla. 2d DCA 2010) (“[T]he narrow argument that counsel was ineffective for failing to raise a defendant’s competency is cognizable in a rule 3.850 motion.”), and we conclude that the claim was not conclusively refuted by the record excerpts attached to the postconviction court’s order, see Houle v. State, 74 So.3d 143, 144 (Fla. 1st DCA 2011). Consequently, we remand to the postconviction court to either attach the portions of the record that conclusively refute claim two of Watts’s amended 3.850 motion or to hold an evidentiary hearing on that claim. See Coley v. State, 74 So.3d 184, 185 (Fla. 2d DCA 2011); Cochran v. State, 46 So.3d 1116, 1118 (Fla. 2d DCA 2010).
Affirmed in part, reversed in part, and remanded.
CASANUEVA and LaROSE, JJ., Concur.
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Authorities Cited
- AKE v. Oklahoma, 470 U.S. 68 (U.S. 1985)
- Whitfield v. State, 923 So. 2d 375 (Fla. 2005)
- Coley v. State, 74 So. 3d 184 (Fla. 2d DCA 2011)
- Heath A. Demarco v. State, 31 So. 3d 975 (Fla. 2d DCA 2010)
- Houle v. State, 74 So. 3d 143 (Fla. 1st DCA 2011)
- Cochran v. State, 46 So. 3d 1116 (Fla. 2d DCA 2010)