Wainwright v. State
The First DCA largely affirmed the denial of Wainwright's rule 3.850 motion but reversed as to one legally insufficient subclaim of ground four, holding that rule 3.850(h)(3) required a nonappealable order granting sixty days to amend. The court also addressed COVID-era masking IAC claims, holding that jurors are not witnesses for Confrontation Clause purposes and that a witness-masking claim fails absent a particularized showing of prejudice.
Key facts
- Wainwright filed a rule 3.850 motion for postconviction relief raising multiple grounds, including claims that his counsel was ineffective for failing to object to masking of jurors and witnesses during trial.
- The postconviction court denied Wainwright's rule 3.850 motion, but did not expressly address one legally insufficient subclaim within ground four.
- +2 more key facts with a free trial
Why it matters
Useful for postconviction practitioners handling COVID-era masking IAC claims: the opinion draws a clear line between juror masking (no Confrontation Clause interest) and witness masking (potential constitutional issue… — full analysis with a trial
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