Henry Martin Steiger v. State of Florida, 328 So.3d 926

Henry Steiger was convicted of second-degree murder and on direct appeal raised claims that his trial counsel was ineffective, but those claims were unpreserved and he did not allege fundamental error.
The First District declined to reach the unpreserved ineffective-assistance claims, citing section 924.051(3), which limits direct-appeal review of unpreserved errors to instances of fundamental error.
Other district courts (Howard, Kruse) and this Court in Monroe had previously reviewed and granted relief on certain unpreserved ineffective-assistance claims when error was apparent on the face of the record to avoid waste of judicial resources.
The Supreme Court accepted review to resolve the direct conflict among the districts about whether appellate courts may address unpreserved ineffective-assistance claims on direct appeal without a fundamental-error allegation.
The Court held that the plain text of section 924.051(3) precludes appellate review of unpreserved ineffective-assistance claims on direct appeal unless the defendant demonstrates fundamental error; otherwise such claims must be raised in a postconviction motion under the Strickland standard.
The Court rejected constitutional and separation-of-powers challenges to applying §924.051(3) as a permissible condition on the right to direct appeal and suggested the Rules Committee consider a procedural rule to allow trial-court resolution of facially obvious IAC claims before full merits briefing on appeal.

Issue	Steiger's Argument	State's Argument	Held
May appellate courts decide unpreserved ineffective-assistance-of-counsel (IAC) claims on direct appeal absent an allegation of fundamental error?	Appellate courts may address facially apparent IAC on direct appeal (waste-of-judicial-resources rationale); Strickland is an adequate, less-demanding avenue to relief.	§924.051(3) bars raising unpreserved errors on direct appeal unless they constitute fundamental error; no judicially created waste-of-resources exception.	§924.051(3) precludes review of unpreserved IAC on direct appeal unless the defendant shows fundamental error; otherwise IAC claims belong in postconviction proceedings under Strickland.
Does applying §924.051(3) to bar direct-appeal review of unpreserved IAC violate the Sixth Amendment or separation of powers?	Conditioning direct-appeal review of IAC may impair the Sixth Amendment right to effective assistance and deny meaningful relief on appeal.	The statute merely conditions the right to direct appeal and is consistent with constitutional limits; IAC claims can be pursued postconviction.	Court rejected the constitutional and separation-of-powers challenges; conditioning appeals on preservation or fundamental-error allegations is permissible.

Strickland v. Washington, 466 U.S. 668 (establishes two-prong standard for ineffective assistance of counsel)
Monroe v. State, 191 So. 3d 395 (Fla. 2016) (previously allowed relief for facially apparent IAC on direct appeal)
Howard v. State, 288 So. 3d 1239 (Fla. 2d DCA 2020) (district court reviewed unpreserved IAC as apparent on record)
Kruse v. State, 222 So. 3d 13 (Fla. 4th DCA 2017) (same—granted relief for unpreserved IAC apparent on record)
State v. Jefferson, 758 So. 2d 661 (Fla. 2000) (interpreting §924.051(3) as conditioning reversal on preserved error or fundamental error)
Bolin v. State, 41 So. 3d 151 (Fla. 2010) (discussing Strickland deficiency and prejudice requirements)
Maxwell v. Wainwright, 490 So. 2d 927 (Fla. 1986) (ineffective-assistance analysis referenced for Strickland-related principles)
F.B. v. State, 852 So. 2d 226 (Fla. 2003) (defining fundamental error as one that undermines trial validity)
Brown v. State, 124 So. 2d 481 (Fla. 1960) (classic statement on fundamental error)
State v. Maisonet-Maldonado, 308 So. 3d 63 (Fla. 2020) (statutory interpretation confirming plain-meaning application of §924.051)