MICHAEL D. EDWARDS, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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Michael Edwards appealed a trial court's summary denial of his rule 3.850 postconviction motion. The appellate court affirmed the denial of most grounds but reversed on a Brady v. Maryland claim regarding suppressed evidence, finding the claim facially sufficient and remanding for an evidentiary hearing.
The court held that Edwards's Brady claim is facially sufficient and not conclusively refuted by the record. Accepting Edwards's allegations as true, he demonstrated that each piece of evidence was favorable to him and that suppression prejudiced him. The trial court's summary denial was improper because the court misunderstood the nature of Edwards's allegation.
[1] A claim alleging the State suppressed evidence in violation of Brady v. …
[2] A trial court's summary denial of a postconviction relief claim is reversible if the claim is facially sufficient and not conclusively refuted by the record.
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“Appellant's allegation does not rise to a Brady violation because the State did not suppress evidence.”
Establishes the trial court's initial erroneous reasoning in denying the claim
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceEdwards was convicted in connection with a robbery. He alleged the State failed to disclose four pieces of evidence: a note requesting leniency for hi…
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PER CURIAM.
Appellant appeals the trial court’s summary denial of his motion for postconviction relief filed pursuant to rule 3.850, Florida Rules of Criminal Procedure (2004). We affirm the trial court’s summary denial on all grounds except one. We find that his claim alleging the State suppressed evidence in violation of Brady v. Maryland, 373 U.S. 83, 83 S.Ct. 1194, 10 L.Ed.2d 215 (1963), is facially sufficient and is not conclusively refuted by the record. Accordingly, we reverse the trial court’s order summarily denying this claim and remand for either an evidentiary hearing or for the court to attach further portions of the record which conclusively refute Appellant’s claim. See Fla. R.Crim. P. 3.850(d).
Appellant alleges that a violation of Brady occurred when the State failed to disclose four significant pieces of evidence to the defense: (1) a note to the trial judge requesting leniency for his co-defendant; (2) co-defendant’s pretrial statement that the gun used during the robbery was a “cap gun”; (3) video surveillance from the crime scene; and (4) a forensic report noting that a positive identification of Appellant’s footprint could not be made.
The trial court interpreted Appellant’s claim as alleging that his original trial counsel failed to deliver certain discovery items to his replacement counsel. The trial court denied this claim, concluding that Appellant’s allegation does not rise to a Brady violation because the State did not suppress evidence. The court did not attach any record portions to support its summary denial of this claim.
As Appellant argues in his initial brief, and the State concedes, the trial court misunderstood Appellant’s allegation. Appellant never alleged that his original counsel failed to supply the evidence to replacement counsel; he stated that his original counsel agreed to participate in reciprocal discovery with the State, but the State did not comply. Accepting Appellant’s allegations as true, he has made a facially sufficient claim that a Brady violation occurred, as he has shown that each piece of evidence was favorable to him and that the State’s suppression of it preju diced him. We therefore reverse the trial court’s summary denial of Appellant’s facially sufficient claim and remand for further proceedings consistent with this opinion.
AFFIRMED in part, REVERSED in part, and REMANDED.
BROWNING, C.J., KAHN and THOMAS, JJ., concur.