State v. Isaac L. Anderson, Jr., 215 So. 3d 181

Isaac Anderson was convicted of two counts of aggravated battery on police officers with a deadly weapon, one count of fleeing and eluding, and one count of resisting arrest without violence after a multi-vehicle takedown and a five‑mile pursuit.
Anderson filed a Florida Rule of Criminal Procedure 3.850 motion alleging ineffective assistance of trial counsel (11 grounds). Grounds Three and Eight alleged failure to call passenger Laron Johnson and failure to present an accident reconstruction expert, respectively.
After an evidentiary hearing, the postconviction court found counsel’s performance deficient on Grounds Three and Eight, vacated and set aside all four convictions, and summarily denied the remaining grounds.
The State appealed only the portion of the order that vacated the fleeing and eluding and resisting without violence convictions (it did not appeal the vacatur of the aggravated battery convictions).
At trial Anderson admitted fleeing the scene and running from police; Ground Three did not claim Johnson’s testimony would affect fleeing/resisting counts, and the reconstruction expert performed no analysis of damage occurring after the initial collisions.
The Fifth District reviewed deference to factual findings and de novo legal conclusions under Strickland’s deficient-performance and prejudice standard.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Anderson)	Held
Whether vacatur of fleeing and resisting convictions was authorized by relief granted only on Grounds Three and Eight	Vacatur of those counts was improper because Grounds Three and Eight related only to aggravated battery	Grounds Three and Eight required vacatur of all convictions because counsel's failures undermined entire verdict	Reversed as to fleeing and resisting convictions; relief was limited to aggravated battery convictions
Whether failure to call Johnson prejudiced Anderson's fleeing and eluding and resisting convictions	No prejudice: Anderson admitted fleeing and running, and Ground Three did not allege Johnson's testimony would affect those counts	Johnson's testimony and expert evidence would have undermined State's broader case, affecting all counts	No prejudice as to fleeing and resisting: Anderson's admissions and the scope of the grounds precluded Strickland prejudice

Strickland v. Washington, 466 U.S. 668 (establishes deficient performance and prejudice standard for ineffective assistance of counsel)
Hitchcock v. State, 991 So. 2d 337 (Fla. 2008) (standard for mixed questions of law and fact in postconviction ineffective-assistance review)
Sochor v. State, 883 So. 2d 766 (Fla. 2004) (deference to postconviction factual findings)
Coney v. State, 845 So. 2d 120 (Fla. 2003) (review standards for postconviction proceedings)
Occhicone v. State, 768 So. 2d 1037 (Fla. 2000) (prejudice assessed in context of the entire record)
Larry v. State, 61 So. 3d 1205 (Fla. 5th DCA 2011) (application of Strickland in this district)
Morris v. State, 931 So. 2d 821 (Fla. 2006) (Strickland elements explained in Florida context)
United States v. Ausmus, 774 F.2d 722 (6th Cir. 1985) (no Strickland prejudice where defendant admitted culpable conduct)
Gibson v. State, 835 So. 2d 1159 (Fla. 2d DCA 2002) (no prejudice where defendant admitted offense in police interview)