Saunders v. State
148 So. 3d 843
| Fla. Dist. Ct. App. | 2014Background
- Defendant Oberist Saunders pleaded no contest to trafficking in oxycodone (Count I) in an open plea with a substantial-assistance provision; adjudication was withheld on Counts II–V.
- Saunders later failed to provide the agreed assistance and was arrested on new charges; he entered a new no-contest plea and received a mandatory three-year sentence.
- Saunders did not pursue a direct appeal but filed a Florida Rule of Criminal Procedure 3.850 post-conviction motion raising four grounds alleging ineffective assistance and newly discovered evidence.
- The trial court summarily denied all four claims but did not attach record documents to its denial order.
- The State conceded error as to certain claims because the denial lacked attached records conclusively refuting them.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| I. Counsel failed to advise/pursue all defenses | State: trial court properly denied | Saunders: counsel ineffective for not pursuing available defenses | Remanded — trial court must attach records refuting claim or hold evidentiary hearing |
| II. Counsel failed to inquire into competency/mental health | State: trial court properly denied | Saunders: counsel ineffective for not investigating competency/mental health | Remanded — trial court must attach records refuting claim or hold evidentiary hearing |
| III. Plea involuntary due to mental illness/medication | State: trial court properly denied | Saunders: plea involuntary because of mental illness/medication | Remanded — plea transcript/record absent; evidentiary hearing or record attachments required |
| IV. Newly discovered evidence (hypothyroidism) | State: denial proper | Saunders: medical diagnosis would have changed outcome | Affirmed — Saunders failed to tie condition to time of offense, plea, or sentencing; no prejudice shown |
Key Cases Cited
- Jones v. State, 998 So.2d 573 (Fla. 2008) (Strickland standard applied to ineffective-assistance claims)
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong test for ineffective assistance of counsel)
- Phillips v. State, 894 So.2d 28 (Fla. 2004) (entitlement to evidentiary hearing unless record conclusively refutes claim)
- Hill v. State, 611 So.2d 115 (Fla. 5th DCA 1993) (trial court must attach record portions when summarily denying a 3.850 motion)
- Young v. State, 789 So.2d 1160 (Fla. 5th DCA 2001) (reversal where claim not conclusively refuted and plea hearing transcript absent)