CHRISTOPHER WHEELER
v.
STATE OF FLORIDA
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A trial court must either explain the rationale for denying a postconviction motion or attach portions of the record that conclusively refute the claims; summary denial without either is reversible error.
[1] A claim of ineffective assistance of counsel based on the failure to investigate potential witnesses is legally insufficient if the defendant fails to explain how the omi…
[2] A claim of ineffective assistance of counsel based on the failure to utilize exculpatory videotapes is legally sufficient and should not be summarily denied without the a…
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Court's statement of the legal requirement for summary denial of postconviction motions under Morris v. State and Florida Rule of Criminal Procedure 3.850(f)(5)
Christopher Wheeler appealed a trial court's denial of his Rule 3.850 postconviction motion. The trial court summarily denied the motion without provi…
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PER CURIAM.
Appellant, Christopher Wheeler, appeals the trial court’s denial of his Florida Rule of Criminal Procedure 3.850 motion for postconviction relief. The trial court summarily denied Appellant’s motion without providing a legal basis or attaching portions of the record that conclusively refute the claims.
When a trial court summarily denies a postconviction motion, “it must either explain the rationale for the denial, or attach those portions of the record that conclusively refute the claims.” Morris v. State, 287 So. 3d 634, 635 (Fla. 4th DCA 2020); see also Fla. R. Crim. P. 3.850(f)(5) (providing that if a motion is legally sufficient but the grounds listed therein can be conclusively resolved by reliance upon the record, the portion of the record that conclusively shows that the defendant is not entitled to relief must be attached to the order).
The State concedes that the trial court’s order does not comply with the Rule. Accordingly, we reverse and remand for the trial court to explain its rationale or attach portions of the record that conclusively refute Appellant’s claims.
Reversed and remanded for further proceedings consistent with this opinion. MAY, CONNER and KLINGENSMITH, JJ., concur. * * * Not final until disposition of timely filed motion for rehearing.