Campoverde v. State
The Sixth DCA held that a criminal defendant's pro se notice of appeal, filed while still represented by trial counsel with no order of withdrawal, is a legal nullity under Logan v. State and does not invoke appellate jurisdiction. The court dismissed the appeal but noted the defendant could pursue a belated appeal under Rule 9.141(c) if warranted.
Key facts
- Criminal defendant filed a pro se notice of appeal while still represented by trial counsel, with no court order permitting counsel's withdrawal.
- The trial court and appellate record showed counsel of record remained active and did not adopt or authorize the pro se notice of appeal.
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Why it matters
This opinion gives criminal appellate practitioners a clear, well-organized roadmap for handling pro se notices of appeal filed by represented defendants, an increasingly common jurisdictional trap, especially where… — full analysis with a trial
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