Legal Opinion · Concurrence

Sheena Latson v. State of Florida

District Court of Appeal of Florida

Decided June 17, 2016No. 1D12-3620Published

1ConcurrenceWinokur, J.

In' this appeal,.appellant does not raise a single claim of preserved error or even a claim that any error below is fundamental; *1072Instead, appellant identifies numerous alleged specific instances of “ineffective assistance of counsel on the face of the record,” and seeks correction of a scrivener’s error that she never asked the trial court to correct. I concur in the majority opinion, but write separately to discuss the growing frequency of claims of “ineffective assistance of counsel on the face of the record” as an unjustifiable substitute for claims of fundamental error.

A. Appellate review…

2Cases cited24 opinions

  1. Strickland v. WashingtonSupreme Court of the United States · 1984
  2. Brady v. MarylandSupreme Court of the United States · 1963
  3. Giglio v. United StatesSupreme Court of the United States · 1972
  4. McMann v. RichardsonSupreme Court of the United States · 1970
  5. State v. DelvaSupreme Court of Florida · 1991

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