Ross v. State
The Third DCA treated Ross's appeal of a summary denial of his pro se rule 3.800(c) sentence-reduction motion as a petition for writ of certiorari, since such discretionary orders are not directly appealable. The trial court had denied the motion solely because it was not adopted by defense counsel, but the court held that Logan v. State's bar on pro se filings by represented defendants did not apply because Ross was unrepresented when he filed the motion.
Key facts
- Ross, an unrepresented defendant, filed a pro se rule 3.800(c) motion for sentence reduction after his representation had ended.
- The trial court denied Ross's motion solely because it was not adopted by his former defense counsel.
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Why it matters
This opinion clarifies a recurring procedural trap in sentence-reduction practice: trial courts sometimes reflexively deny pro se 3.800(c) motions for lack of defense-counsel adoption even when the movant is no longer… — full analysis with a trial
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