Woodberry v. State

Appellant, at trial, was represented by court-appointed counsel. Another attorney appeared for appellant at sentencing. Appellant argues on appeal that this substitution of counsel rendered the sentencing hearing fundamentally unfair and constitutionally deficient. We decline to adopt a rule that such substitution constitutes reversible error per se. Each case must proceed on its own facts, and the burden is on appellant to demonstrate that his rights were prejudiced by the substitution. Eutzy v. State, 536 So.2d 1014, 1015 (Fla.1988) (to support a claim of ineffective assistance of counsel,…