Debose v. State
On rehearing, the First District reaffirmed that Florida Rule of Appellate Procedure 9.200(f) (record supplementation) is not the proper mechanism for obtaining transcription of hearings at public expense for appellate review; that process is governed instead by Fla. R. Gen. Prac. & Jud. Admin. 2.535 and each circuit's court-reporting plan, or by statutory public defender/JAC funding mechanisms. The court explained that appointed appellate counsel must first obtain needed transcripts through the trial court/circuit court-reporting plan (or free rough-draft copies), and only after obtaining them may counsel move under rule 9.200(f) to add them to the appellate record. Judge Kelsey noted a dissent to follow, indicating some disagreement on the court's approach.
Key facts
- Debose was an indigent criminal defendant represented by appointed appellate counsel seeking to obtain transcripts of trial court hearings not already in the appellate record.
- Debose's appellate counsel moved to supplement the appellate record under Florida Rule of Appellate Procedure 9.200(f), seeking public funding for transcription of the hearings.
- +2 more key facts with a free trial
Why it matters
This opinion gives criminal appellate practitioners, particularly public defenders and appointed appellate counsel, a clear procedural roadmap for securing publicly funded transcripts of hearings not already in the… — full analysis with a trial
🔒 Read the full opinion, holding & search the library
The full opinion PDF, the rules the court applied, our significance analysis, the background facts, and full-text search across every tracked Florida decision are available to members. Start a free 30-day trial — no credit card.
Not ready to sign up? Get the free Friday digest — the week's key Florida decisions by email, no login required.
Florida Court Tracker provides summaries of publicly available court opinions for informational and research purposes only. This is not legal advice and does not create an attorney–client relationship. Always verify holdings against the official opinion.