Jackson v. State
The Second DCA reversed in part the summary denial of a 3.850 motion alleging ineffective assistance for failing to object to unrequested costs of prosecution and investigative costs lacking supporting evidence. The court clarified that the modified Grosvenor/Long prejudice standard (requiring allegation that defendant would not have pleaded guilty) applies only to deficiencies related to entry of the plea, not to post-plea sentencing errors, so ordinary Strickland prejudice sufficed here.
Key facts
- Jackson sought post-conviction relief under Florida Rule of Criminal Procedure 3.850, claiming his trial counsel was ineffective for failing to object to costs of prosecution and investigative costs imposed at sentencing that lacked proper statutory support.
- The trial court summarily denied the motion without addressing the substance of Jackson's allegations or attaching record portions to refute them.
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Why it matters
This opinion gives postconviction practitioners a clear rule for distinguishing when the modified (plea-specific) Strickland prejudice standard applies versus the ordinary Strickland standard: the Grosvenor/Long test is… — full analysis with a trial
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