Matthews v. State
The Third DCA affirmed denial of Matthews' 3.850 motion for postconviction relief based on newly-discovered evidence—an affidavit from co-defendant Naylor exculpating Matthews. At the evidentiary hearing, Naylor invoked his Fifth Amendment right to avoid cross-examination about his own involvement in the murder, and his testimony revealed he lacked personal knowledge of Matthews' non-involvement. The court held the trial court did not abuse its discretion in finding Naylor's testimony inadmissible at any retrial, both because it was speculative and lacked personal knowledge, and because Naylor's refusal to submit to full cross-examination on material matters warranted exclusion.
Key facts
- Matthews was convicted and sought postconviction relief under Rule 3.850 based on a newly-discovered affidavit from co-defendant Naylor claiming Matthews was not involved in the murder.
- At the evidentiary hearing on the 3.850 motion, Naylor testified but invoked his Fifth Amendment privilege to avoid cross-examination about his own involvement in the murder and revealed he lacked personal knowledge of Matthews' non-involvement.
- +2 more key facts with a free trial
Why it matters
This opinion gives postconviction practitioners a clear framework, extending Fourth DCA precedent (Sule, Maul) into the newly-discovered-evidence context, for how courts should treat an exculpatory co-defendant… — 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.