Moore v. State, 225 So. 3d 307

Clarence Moore appealed the summary denial of his Florida Rule of Criminal Procedure 3.850 motion alleging trial counsel was ineffective for failing to object to improper prosecutorial comments during closing argument.
The trial record contained four contested comments; however, only two were raised in Moore's operative 3.850 motion and preserved for appellate review.
The trial court denied relief without an evidentiary hearing; Moore challenged that denial on appeal.
The appellate court analyzed Moore’s claim under the Strickland two-prong ineffective-assistance standard (deficient performance and prejudice).
The court concluded the prosecutor’s remarks were not improper; even if improper, they were brief and isolated and did not satisfy Strickland prejudice.
The court affirmed the summary denial, noting counsel cannot be ineffective for failing to object to meritless comments and that any objection likely would have led only to a curative instruction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial counsel was ineffective for not objecting to alleged improper prosecutorial comments in closing	Moore: Counsel’s failure to object to four (two preserved) improper comments constituted ineffective assistance	State: Comments were not improper; even if improper, failure to object was not prejudicial; meritless objections cannot show ineffective assistance	Court: Comments were not improper; alternatively, no Strickland prejudice — affirmed summary denial

Strickland v. Washington, 466 U.S. 668 (established two-prong ineffective-assistance standard)
Teffeteller v. Dugger, 734 So. 2d 1009 (Fla. 1999) (counsel not ineffective for failing to object to meritless arguments)
Castor v. State, 365 So. 2d 701 (Fla. 1978) (issues not raised below generally not considered on appeal)