Woodbury v. State / Woodbury v. Secretary, Department of Corrections
In a capital postconviction appeal and companion habeas petition, the Florida Supreme Court affirmed the summary denial of Woodbury's 3.851 motion and denied his habeas petition alleging ineffective appellate counsel. The Court held his Brady claim was insufficiently pled because he never alleged the mental health records were unavailable to the defense, several claims were procedurally barred as raisable on direct appeal, a pro se defendant cannot claim ineffective assistance of standby counsel, and his shackling/prison-garb claim was unpreserved and did not amount to fundamental error given his violent history and pro se status.
Key facts
- Woodbury, a pro se capital defendant, filed a 3.851 postconviction motion and habeas petition challenging his conviction and death sentence based on Brady violations, ineffective appellate counsel, and shackling/prison-garb claims.
- The trial court summarily denied the 3.851 motion and the habeas petition was denied, finding the Brady claim insufficiently pled, several claims procedurally barred, and the shackling claim unpreserved.
- +2 more key facts with a free trial
Why it matters
This opinion is a useful, if largely reaffirming, resource for capital and non-capital postconviction practitioners on several recurring issues: the pleading requirements for a Brady claim (must allege unavailability to… — full analysis with a trial
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