Michael S. Ratley v. State of Florida

Michael S. Ratley appeals the denial of his claim of ineffective assistance of trial counsel. Because Ratley is entitled to an evidentiary hearing on his claim, the summary denial of relief was erroneous.

Following the affirmance of his conviction and sentence for the first degree murder of his wife, Ratley timely filed a motion for post-conviction relief on the authority of rule 3.850, Florida Rules of Criminal Procedure. In his motion, he raised four claims of ineffective assistance of trial counsel. In his first claim, Ratley asserted trial counsel rendered ineffective assistance for…