Minix v. State
Minix v. State
Opinion of the Court
Corey A. Minix appeals the summary denial of his Florida Rule of Criminal Procedure 3.850 motions for postconviction relief. We affirm the summary denial of all grounds raised in Minix's motions, except ground six of his first motion. In that ground, Minix alleged that his plea was involuntary because his trial counsel failed to investigate and raise a prescription defense to the charge of trafficking in a controlled substance. The postconviction court denied this claim, finding that Minix's voluntary plea waived his right to present defenses to a jury. Relying on Stano v. State,
The postconviction court's reliance on Stano is misplaced in that a general waiver of defenses is insufficient to refute a more specific claim. See Prestano v. State,
"A trial attorney's failure to investigate a factual defense ... which results in the entry of an ill-advised plea of guilty, has long been held to constitute a facially sufficient attack upon the conviction." Guzman-Aviles v. State,
Therefore, we reverse the summary denial as to ground six only and remand to the trial court to grant Minix leave to amend his rule 3.850 motion to state a sufficient claim.
AFFIRMED IN PART, REVERSED IN PART, and REMANDED.
ORFINGER and EISNAUGLE, JJ., concur.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.