Inchierchiere v. State

Affirmed. As to the claim that counsel failed to file a timely motion to disqualify the trial judge, claims of ineffective assistance of postconviction counsel do not present a valid claim, as there is no constitutional right to collateral counsel. Zack v. State, 911 So.2d 1190, 1203 (Fla. 2005). Further, appellant wanted to disqualify the judge from ruling on a motion to mitigate a sentence pursuant to Florida Rule of Criminal Procedure 3.800(c). A rule 3.800(c) motion is a collateral proceeding, “not a de novo proceeding complete ‘with the full array of due process rights.’” Fox v. State,…