Woodson v. State
100 So. 3d 222
| Fla. Dist. Ct. App. | 2012Background
- Woodson petitioned for writ of habeas corpus alleging manifest injustice from this Court’s 1999 affirmance of his direct appeal.
- Claim in 1999: invalid charging document not based on sworn material witness statement under Fla. R. Crim. P. 3.140; issue deemed not preserved in trial court.
- This petition presents no new change in circumstances or caselaw to justify review after thirteen years.
- Woodson has filed at least fifteen proceedings in this Court since the 1999 appeal; at least eight raised the same merits claim.
- Court finds Woodson has pursued meritless, frivolous, and successive collateral challenges, wasting judicial resources.
- Court directs Woodson to show cause within 30 days why he should not be barred from further pro se filings in the cited Florida circuit court case, absent good cause, and warns of sanctions including potential gain-time forfeiture.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the petition is barred as a successive collateral claim. | Woodson contends relief is warranted. | Court may bar repetitive pro se filings. | Petition dismissed; court may impose filing restrictions. |
| Whether pro se filings may be restricted to protect the judicial process. | Pro se rights must be protected. | Rights may be curtailed for abuse of process. | Court may sanction and restrict further pro se filings after notice and hearing. |
| Whether there is good cause to permit further pro se filings. | Woodson asks for access to continue proceedings. | No good cause shown. | Absent good cause, filings will be refused and sanctions may follow. |
| Whether procedural abuse justifies directing sanctions under Fla. stat. | N/A (not favorable to Woodson) | N/A | Sanctions, including potential forfeiture of gain time, may be imposed. |
Key Cases Cited
- State v. Spencer, 751 So.2d 47 (Fla.1999) (limits pro se access when abuse of process is shown)
- Isley v. State, 652 So.2d 409 (Fla.5th DCA 1995) (enough is enough; limits on frivolous filings)
- Hedrick v. State, 6 So.3d 688 (Fla.4th DCA 2009) (frivolous claims burden judicial resources)
- Woodson v. State, 95 So.3d 238 (Fla.3d DCA 2012) (sanctions and restrictive measures against repeated pro se petitions)
- Woodson v. State, 90 So.3d 296 (Fla.3d DCA 2012) (continuing pattern of successive collateral challenges)
- Woodson v. State, 76 So.3d 308 (Fla.3d DCA 2011) (reiterates pro se filing concerns)
- Woodson v. State, 67 So.3d 218 (Fla.3d DCA 2011) (same lineage of pro se filings)
- Woodson v. State, 35 So.3d 35 (Fla.3d DCA 2010) (earlier warnings on frivolous filings)
- Woodson v. State, 993 So.2d 533 (Fla.3d DCA 2008) (precedent for dismissing meritless claims)
- Woodson v. State, 972 So.2d 196 (Fla.3d DCA 2007) (continuing pattern of pro se filings)
- Woodson v. State, 917 So.2d 878 (Fla.3d DCA 2005) (early stage warnings and sanctions approach)