Florida Case Commentaries

Rhodes v. State (Fla. 2026): Decades-Late Jailhouse Recantations—Absent Credible Proof—Do Not Establish Brady/Giglio/Massiah Violations or Newly Discovered Evidence in Successive Death Postconviction

Date: Jul 3, 2026

Rhodes v. State (Fla. 2026): Decades-Late Jailhouse Recantations—Absent Credible Proof—Do Not Establish Brady/Giglio/Massiah Violations or Newly Discovered Evidence in Successive Death Postconviction...

Florida Probate Rules Conformed to Renamed Rule 2.516 (“Service”) and Rule 2.525 (“Filing”) and Updated for Modern Rule-Drafting Standards

Date: Jul 2, 2026

Florida Probate Rules Conformed to Renamed Rule 2.516 (“Service”) and Rule 2.525 (“Filing”) and Updated for Modern Rule-Drafting Standards 1) Introduction In In Re: Amendments to Florida Probate...

Florida Appellate Briefing Now Requires a Jurisdictional Statement and Issue-by-Issue Preservation/Standard-of-Review Disclosures

Date: Jul 2, 2026

Florida Appellate Briefing Now Requires a Jurisdictional Statement and Issue-by-Issue Preservation/Standard-of-Review Disclosures Case: In Re: Amendments to Florida Rules of Appellate Procedure...

No Suppression Remedy for Violations of Florida’s Search-Warrant Knock-and-Announce Statute (Receding from State v. Cable)

Date: Jul 2, 2026

No Suppression Remedy for Violations of Florida’s Search-Warrant Knock-and-Announce Statute (Receding from State v. Cable) Introduction In State of Florida v. Keith Alexander Times (Fla. June 25,...

Roberts v. State (Fla. 2026): Case-by-Case “Meaningful” Nunc Pro Tunc Competency Determinations; No Bright-Line Evidentiary Requirements

Date: Jul 2, 2026

Roberts v. State (Fla. 2026): Case-by-Case “Meaningful” Nunc Pro Tunc Competency Determinations; No Bright-Line Evidentiary Requirements I. Introduction In William F. Roberts v. State of Florida, the...

Florida District Courts Have Jurisdiction to Review Denials of Downward Departure Sentences

Date: Jun 19, 2026

Florida District Courts Have Jurisdiction to Review Denials of Downward Departure Sentences Case: Eric Desmond Parrish v. State of Florida Court: Supreme Court of Florida Date: June 18, 2026 Author:...

Whitton v. State (Fla. 2026): Due-Diligence “Discoverability” (Not Later Testimony) Triggers the One-Year Window for Successive Newly-Discovered-Evidence Claims in Capital Postconviction

Date: Jun 19, 2026

Whitton v. State (Fla. 2026): Due-Diligence “Discoverability” (Not Later Testimony) Triggers the One-Year Window for Successive Newly-Discovered-Evidence Claims in Capital Postconviction Case: Gary...

Post-Warrant Claims Must Satisfy Rule 3.851 Discoverability; No Eighth Amendment Elderly Exemption in Florida

Date: Jun 19, 2026

Post-Warrant Claims Must Satisfy Rule 3.851 Discoverability; No Eighth Amendment Elderly Exemption in Florida I. Introduction In Dusty Ray Spencer v. State of Florida (Fla. June 18, 2026), the...

Scientific Consensus on Late Brain Development Is Not “Newly Discovered Evidence” in Successive Florida Death-Penalty Postconviction Motions

Date: Jun 19, 2026

Scientific Consensus on Late Brain Development Is Not “Newly Discovered Evidence” in Successive Florida Death-Penalty Postconviction Motions I. Introduction In Harold Lee Harvey, Jr. v. State of...

Florida Probate Rules (2026): Curatorship Letters Must Specify Powers and PR Eligibility Disclosures Track Elder-Abuse Statutes

Date: Jun 19, 2026

Florida Probate Rules (2026): Curatorship Letters Must Specify Powers and PR Eligibility Disclosures Track Elder-Abuse Statutes 1. Introduction In In Re: Amendments to Florida Probate Rules, the...

Woodbury (Fla. 2026): Procedural Bars and Preservation Apply Fully to Pro Se Capital Defendants; Brady Pleading Must Allege Defense Unavailability; No IAC Claim Against Standby Counsel

Date: Jun 12, 2026

Woodbury (Fla. 2026): Procedural Bars and Preservation Apply Fully to Pro Se Capital Defendants; Brady Pleading Must Allege Defense Unavailability; No IAC Claim Against Standby Counsel I....

Mandatory Jurisdictional Statements and Issue-by-Issue Standards of Review in Florida Initial Briefs

Date: Jun 12, 2026

Mandatory Jurisdictional Statements and Issue-by-Issue Standards of Review in Florida Initial Briefs Case: In Re: Amendments to Florida Rules of Appellate Procedure Court: Supreme Court of Florida...

Section 768.72(1) Gatekeeping: Claimant-Only Evidentiary Proffer and No “Clear and Convincing” Overlay at the Pleading Stage

Date: Jun 12, 2026

Section 768.72(1) Gatekeeping: Claimant-Only Evidentiary Proffer and No “Clear and Convincing” Overlay at the Pleading Stage I. Introduction In Isaac “Ike” Perlmutter v. Federal Insurance Company...

All Writs Is Not Jurisdiction: Florida Supreme Court Will Not Intervene in Pending DCA Nonfinal Injunction Appeals Absent an Independent Constitutional Hook

Date: Jun 11, 2026

All Writs Is Not Jurisdiction: Florida Supreme Court Will Not Intervene in Pending DCA Nonfinal Injunction Appeals Absent an Independent Constitutional Hook 1. Introduction In Equal Ground Education...

Florida IOTA Rate Rule: Prime Minus 300 bps (Net of Fees) with 0.25% Floor and 1.50% Cap

Date: Jun 7, 2026

Florida IOTA Rate Rule: Prime Minus 300 bps (Net of Fees) with 0.25% Floor and 1.50% Cap 1. Introduction In In Re: Amendments to Rules Regulating the Florida Bar - Rule 5-1.1, the Supreme Court of...

Florida PSC May Approve RSAM-Adjusted Depreciation and RSAM in a Litigated Rate Case, and Depreciation Rule Does Not Bar Reserve-Surplus-Creating Parameters

Date: Jun 7, 2026

Florida PSC May Approve RSAM-Adjusted Depreciation and RSAM in a Litigated Rate Case, and Depreciation Rule Does Not Bar Reserve-Surplus-Creating Parameters Case: Citizens of the State of Florida,...

Method-of-Execution Claims Must Be Timely and Plead a Feasible Alternative; 32‑Day Death Warrants Do Not Deny Due Process

Date: May 30, 2026

Method-of-Execution Claims Must Be Timely and Plead a Feasible Alternative; 32‑Day Death Warrants Do Not Deny Due Process I. Introduction In Andrew Richard Lukehart v. State of Florida (Fla. May 27,...

Florida Private Whistle-Blower Act § 448.102(3): No “Reasonable Belief” Standard—Plaintiff Must Prove the Objected-to Practice Is (Definitionally) Unlawful

Date: May 29, 2026

Florida Private Whistle-Blower Act § 448.102(3): No “Reasonable Belief” Standard—Plaintiff Must Prove the Objected-to Practice Is (Definitionally) Unlawful Case: Clint Shannon Gessner v. Southern...

Guilt-Phase Unanimous Felony Verdicts Satisfy Poole’s Jury-Finding Requirement for Florida Death Sentences

Date: May 22, 2026

Guilt-Phase Unanimous Felony Verdicts Satisfy Poole’s Jury-Finding Requirement for Florida Death Sentences I. Introduction In Darious Wilcox v. State of Florida (SC2023-1498) and the companion habeas...

Apprendi/Alleyne Sentencing Claims Are Not “Illegal Sentence” Errors Cognizable Under Florida Rule 3.800(a)

Date: May 20, 2026

Apprendi/Alleyne Sentencing Claims Are Not “Illegal Sentence” Errors Cognizable Under Florida Rule 3.800(a) Case: Marcus Roland Maye v. State of Florida, No. SC2023-1184 (Fla. May 14, 2026)...