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Keywords

appealpleamotionhabeas corpuscriminal procedure
jurisdictionmotionhabeas corpuscriminal procedure

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Baker v. State, 878 So.2d 1236, 29 Fla. L. Weekly S105, 29 Fla. L. Weekly S413

Facts

Petitioners Darrell Baker, Deryl Brooks, and Jamie Edward Sly were convicted of various crimes in Florida and sought writs of habeas corpus to challenge their convictions. Baker was convicted of armed robbery, Brooks of various crimes with an affirmed appeal, and Sly of first-degree murder and burglary. Each petitioner raised claims regarding jury selection and the voluntariness of their pleas, but none followed the proper procedural route for postconviction relief as outlined in Florida Rule of Criminal Procedure 3.850.

Petitioners Darrell Baker, Deryl Brooks, and Jamie Edward Sly have filed petitions for writs of habeas corpus, see art. V, § 3(b)(9), Fla. Const., collaterally attacking their noncapital convictions for various crimes committed in this state.

Issue

Whether the petitions for writs of habeas corpus filed by the petitioners were authorized and whether habeas relief was available for obtaining collateral postconviction relief.

Whether the instant petitions were subject to dismissal as unauthorized, and whether habeas relief was available to obtain collateral postconviction relief available by motion in sentencing court pursuant to rule of criminal procedure governing motions to vacate, set aside, or correct sentence.

Rule

Habeas corpus relief is not available in Florida for obtaining collateral postconviction relief that can be sought through a motion in the sentencing court under Florida Rule of Criminal Procedure 3.850.

Thus, this rule essentially transferred consideration of these traditional habeas claims from the court having territorial jurisdiction over the prison where the prisoner is detained to the jurisdiction of the sentencing court.

Analysis

The Court analyzed the procedural history and the intent behind Florida Rule of Criminal Procedure 3.850, concluding that it was designed to provide a mechanism for postconviction relief that would prevent the filing of habeas corpus petitions for claims that could be addressed through motions in the sentencing court. The Court determined that the claims raised by the petitioners were either procedurally barred or did not comply with the time requirements of the rule.

Instead, we conclude that we should dismiss such petitions as unauthorized.

Conclusion

The Supreme Court of Florida dismissed the petitions for writs of habeas corpus as unauthorized, affirming that the proper avenue for the petitioners to seek relief was through motions in the sentencing court under Rule 3.850.

Consistent with the analysis set forth in this opinion, we therefore dismiss the instant petitions as unauthorized.

Who won?

The State prevailed in this case as the Supreme Court dismissed the petitions for writs of habeas corpus, affirming that the petitioners did not follow the proper procedural requirements for postconviction relief.

The Supreme Court consolidated petitions and held that: 1 instant petitions were subject to dismissal as unauthorized, and 2 habeas relief was not available to obtain collateral postconviction relief available by motion in sentencing court pursuant to rule of criminal procedure governing motions to vacate, set aside, or correct sentence.

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