Caldwell v. State
The Fifth DCA affirmed the summary denial of one ground in a 3.850 amended motion but reversed denial of a second ground alleging counsel was ineffective for failing to have the juvenile defendant evaluated for competency before his plea. The postconviction court had improperly treated the new claim as 'unauthorized' because it was added without leave of court, even though it was raised within the two-year filing period and before any final order.
Key facts
- Juvenile defendant Caldwell was convicted after entering a plea; he later filed a rule 3.850 amended motion adding a new ground alleging ineffective assistance of counsel for failure to evaluate competency before the plea.
- The postconviction court summarily denied the new competency claim as 'unauthorized' because it was added to the amended motion without prior leave of court.
- +2 more key facts with a free trial
Why it matters
This opinion reinforces the Gaskin/Padro-Guerrero rule that new claims added to a timely amended 3.850 motion must be considered on the merits rather than rejected as procedurally unauthorized, so long as the two-year… — full analysis with a trial
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