WARREN LEE EDWARDS, APPELLANT,
v.
MICHAEL D. CREWS, SECRETARY, FLORIDA DEPARTMENT OF CORECTIONS, APPELLEE
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Warren Lee Edwards sought a writ of habeas corpus claiming entitlement to immediate release based on deficient pre-arrest probable cause and improper acceptance into custody. The Florida appellate court affirmed the dismissal of his petition, holding that probable cause challenges must be raised at trial or on direct appeal, not through post-conviction habeas corpus, and that administrative deficiencies in custody documentation do not provide grounds for habeas relief.
The court held that challenges to probable cause must be raised at trial and on direct appeal, not through post-conviction habeas corpus. Additionally, administrative deficiencies in custody documentation do not constitute grounds for habeas relief because the statute provides no cause of action for prisoners to challenge their detention based on such documentary omissions.
[1] Claims challenging pre-arrest probable cause must be raised at trial and, if preserved, on direct appeal, and are not a basis for a post-conviction writ of habeas corpus.
[2] A writ of habeas corpus is not available to remedy administrative deficiencies in a prisoner's acceptance into custody.
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Join FLexlaw to unlock all legal intelligence“Appellant's challenge to the judgment and sentence under which he is detained, on the ground that the pre-arrest probable cause affidavits and arrest warrants were faulty, was properly dismissed because such claims must be raised at trial and, if preserved, on direct appeal of the judgment.”
Establishes that probable cause challenges are not cognizable in post-conviction habeas corpus proceedings
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Join FLexlaw to unlock all legal intelligenceEdwards was detained at Century Correctional Institution in Escambia County, Florida. He filed a petition for writ of habeas corpus asserting two grou…
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Warren Lee Edwards appeals the dismissal of his petition for writ of habeas corpus by the circuit court in the county in which he is detained. See § 79.09, Fla. Stat. In the petition for writ of habeas corpus, Edwards asserted that he was entitled to immediate release due to a deficiency in the pre-trial probable cause for his arrest and due to a lack of sufficiency in the paperwork accompanying his acceptance into custody by the Century Correctional Institution in Escambia County, Florida. The dismissal of the petition is affirmed.
Appellant’s challenge to the judgment and sentence under which he is detained, on the ground that the pre-arrest probable cause affidavits and arrest warrants were faulty, was properly dismissed because such claims must be raised at trial and, if preserved, on direct appeal of the judgment. See Zuluaga v. State Dep’t of Corrections, 32 So.3d 674 (Fla. 1st DCA 2010) (rule 3.850, Fla. R. Crim. P., has completely superseded writ of habeas corpus to collaterally challenge a sentence). Challenges to the original probable cause are properly raised at trial and on direct appeal but are not a viable basis for post-conviction relief, Jessie v. State, 726 So.2d 356 (Fla. 5th DCA 1999), or a postconviction writ of habeas corpus.
Considering Appellant’s claim that he was improperly accepted into custody by the Century Correctional Institution without full compliance with section 944.17(5), Florida Statutes, the writ of ha-beas corpus is no,t available to remedy *424such administrative deficiency. While a prisoner might be entitled to correction of his or her commitment file if deficiencies in the documents are discovered, section 944.17(5), Florida Statutes contains no indication that the Florida Legislature created a legal cause of action for prisoners to enforce the documentary requirements therein. See Sykes v. State, 974 So.2d 1138 (Fla.1st DCA 2008). Likewise, the statute does not provide that any omission or lack of compliance by the Department of Corrections or any correctional institution might have any effect upon the validity of the court’s judgment and sentence or confer a liberty interest upon a prisoner. Section 944.17, Florida Statutes does not create a cause of action for prisoners to challenge their detention under a facially valid judgment and sentence and provides no support for any claim of entitlement to immediate release.
The order dismissing the petition for writ of habeas corpus is AFFIRMED.
VAN NORTWICK and OSTERHAUS, JJ., concur.
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Edwards v. State, 192 So. 3d 522 (Fla. 1st DCA 2016)…3d 624 (Fla. 1st DCA 2010); Edwards v. State, 34 So. 3d 4 (Fla. 1st DCA 2010); Edwards v. State, Case No. 1D09-5660; Edwards v. State, Case No. 1D09-5661; Edwards v. State, Case No. 1D11-1769; Edwards v. State, Case No. 1D13-2211; Edwards v. Crews, 124 So. 3d 422 (Fla. 1st DCA 2013); Edwards v. State, 127 So. 3d 505 (Fla. 1st DCA 2013); Edwards v. State, 128 So. 3d 134 (Fla. 1st DCA 2013); Edwards v. State, 139 So. 3d 981 (Fla. 1st DCA 2014); Edwards v. State, Case No. 1D14-2246. . Edwards v. Dep't of Corr.…
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Wilder v. Jones, 202 So. 3d 451 (Fla. 1st DCA 2016)…PER CURIAM. AFFIRMED. Edwards v. Crews, 124 So. 3d 422 (Fla. 1st DCA 2013); Sykes v. State, 31 So. 3d 846 (Fla. 1st DCA 2010). WOLF, BILBREY, and M.K. THOMAS, JJ., concur.…
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Norris Palmer v. Dep't OF Corr. & State of Fla., 209 So. 3d 645 (Fla. 5th DCA 2017)…PER CURIAM. AFFIRMED. See Edwards v. Crews, 124 So. 3d 422, 423 (Fla. 1st DCA 2013). PALMER, ORFINGER and EVANDER, JJ., concur.…
Authorities Cited
- Heldrado Zuluaga v. State, 32 So. 3d 674 (Fla. 1st DCA 2010)
- Ilana Ben-David v. The Educ. Res. Inst., Inc., 974 So. 2d 1138 (Fla. 3d DCA 2008)
- Jessie v. State, 726 So. 2d 356 (Fla. 5th DCA 1999)