WOODS v. STATE (2020)

Jackie W. Woods appeals the summary denial of his amended Florida Rule of Criminal Procedure 3.850 motion for postconviction relief. We reverse.

In August 2017, Woods filed a pro se motion for postconviction relief challenging his conviction in Marion County case number 2012-CF-2372-B. The postconviction court dismissed Woods's motion, explaining that the case Woods referenced had been nolle prossed by the State and consolidated into case number 2012-CF-1122-B. The postconviction court attached a copy of the nolle prosequi to its dismissal order and allowed Woods sixty days to file an amended motion.

Woods timely filed a pro se amended motion for postconviction relief but made the same mistake, again referencing case number 2012-CF-2372-B. The postconviction court denied Woods's motion because “[a]s discussed in this Court's previous order, there is no conviction to challenge in the above-styled case.” It did not provide Woods with another opportunity to amend, noting that Woods had already been afforded one opportunity to amend pursuant to Spera v. State, 971 So. 2d 754 (Fla. 2007).

This was not a situation involving ambiguity concerning which case or charge the defendant wished to challenge. To the contrary, the postconviction court was aware at the time of the initial filing that Woods had inadvertently utilized the wrong case number and knew the correct case number under which Woods intended to raise his postconviction challenge. The postconviction court could have easily noted Woods's scrivener's error and transferred the motion into the correct file. Although we understand the postconviction court's frustration with Woods, “resolution of a case on its merits is preferred and postconviction relief proceedings must provide meaningful access to the judicial process.” James v. State, 185 So. 3d 649, 651 (Fla. 2d DCA 2016) (citing Smith v. State, 100 So. 3d 201, 202 (Fla. 2d DCA 2012)). Under these circumstances, we reverse and remand for the postconviction court to address the merits of Woods's claim. See id. (reversing postconviction court's denial of second amended rule 3.850 motion for failure to include certification that defendant could understand English; postconviction court knew that defendant could understand English despite defendant's failure to include requisite certification because defendant's initial rule 3.850 motion included certification).

REVERSED AND REMANDED with instructions.

COHEN, J.

EISNAUGLE and HARRIS, JJ., concur.