Gallagher v. State
A pro se murder defendant sought certiorari review after the trial court entered a blanket order denying her request to depose the State's Category A witnesses. The Fourth District granted the petition, holding that the trial court departed from the essential requirements of law by categorically barring all depositions without making findings on 'good cause' or considering lesser restrictive measures under Rule 3.220.
Key facts
- Pro se murder defendant petitioned for certiorari review after the trial court issued a blanket order denying her request to depose the State's Category A witnesses without making findings on good cause.
- The trial court categorically barred all depositions of Category A witnesses without considering lesser restrictive protective measures available under Rule 3.220.
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Why it matters
This opinion gives criminal practitioners representing or opposing pro se defendants a concrete standard: trial courts cannot simply deny all discovery depositions wholesale when a defendant proceeds pro se, but must… — full analysis with a trial
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