Koons v. State

Mark Koons seeks review of the trial court’s summary denial of his second Florida Rule of Criminal Procedure 3.850 motion for postconviction relief. We affirm.

Koons’s initial Rule 3.850 motion raised three grounds for relief. The trial court summarily denied that motion, and this Court per curiam affirmed. See Koons v. State, 140 So.3d 597 (Fla. 5th DCA 2014). Koons then filed a successive 3.850 motion, raising nine grounds for relief. The trial court summarily denied the second motion on the ground that it was successive.

Under the current version of Rule 3.850(h)(2), a trial court cannot…