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4th DCANovember 4, 2026Affirmed in part, reversed in part, and remanded⭐ Notable

Jackson v. State

Case No. 4D2025-1862

The Fourth DCA affirmed denial of most of Jackson's rule 3.850 claims but reversed on his claim that trial counsel was ineffective for failing to challenge his dual convictions for dealing in stolen property and grand theft under section 812.025, Florida Statutes. The trial court had erroneously denied the claim based solely on whether the property involved in each count differed, rather than analyzing whether the offenses arose from one scheme or course of conduct.

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Key facts

  • Jackson was convicted of both dealing in stolen property and grand theft under section 812.025, Florida Statutes, based on charges involving property obtained through a single scheme or course of conduct.
  • The trial court denied Jackson's rule 3.850 ineffective assistance of counsel claim regarding the dual convictions, reasoning that the counts involved different property items.
  • +2 more key facts with a free trial

Why it matters

This opinion reaffirms and clarifies that the section 812.025 dual-conviction prohibition turns on whether the theft and dealing offenses arose from one scheme or course of conduct, not on whether the State can… — full analysis with a trial

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