Representative experience

Published decisions, and the briefing behind them.

Each matter below is public record. The filings were researched and drafted by Jabe Carney as a certified inmate law clerk in the Florida Department of Corrections law library program, for litigants representing themselves, who filed them in their own names. The results belong to the courts that reached them, and are described here as the opinions describe them.

Confidential client information and nonpublic work for attorney clients are not disclosed here.

Case study

Howard v. State

Second District Court of Appeal and Supreme Court of Florida · 2015–2021

A juvenile offender serving a parole-eligible life sentence sought resentencing in a pro se postconviction motion. The matter ran six years, through the Supreme Court of Florida and back, and ended in an en banc decision receding from the Second District's own precedent.

2015
The Second District affirmed the denial of the motion. Judge Altenbernd, concurring, described the logic of the appellant's argument as "entirely reasonable."
Howard v. State, 180 So. 3d 1135 (Fla. 2d DCA 2015)
2016
On the appellant's petition, the Supreme Court of Florida quashed the decision and remanded for resentencing. The trial court ordered a new sentencing hearing.
Howard v. State, 41 Fla. L. Weekly S578 (Fla. Oct. 28, 2016)
2019
Before the hearing took place, the governing law changed. The trial court granted the State's motion to deny resentencing, relying on the Second District's decision in Marshall II.
2021
The Second District, sitting en banc, reversed. The trial court lacked authority to disregard the appellate mandate, and the court receded from Marshall II.
Howard v. State, 322 So. 3d 134 (Fla. 2d DCA 2021) (en banc)

Where the briefing shows in the opinion

The State conceded that the trial court could not disregard the mandate. It argued instead that because the underlying motion invoked Rule 3.800, the order granting resentencing was never final and could be rescinded.

The reply brief, handwritten and filed in October 2020, answered that argument: the motion met the pleading requirements of Rule 3.850, so the 2016 order was a final order the trial court had no jurisdiction to revisit, as in Croft v. State. In footnote 3, the en banc court rejected the State's position on that ground and cited Croft.

A supplemental brief filed in December 2020 brought the court two Supreme Court of Florida decisions issued the previous month, State v. Okafor and State v. Jackson. The en banc court held that Okafor controls.

Role

Jabe Carney researched and drafted all of the appellant's pro se filings in this matter, from the postconviction motion through Supreme Court review and the en banc appeal, while serving as a certified inmate law clerk. Howard filed them in his own name.

Additional matters

Juvenile sentencing and sentence enhancement.

Weiand v. State
325 So. 3d 116 (Fla. 5th DCA 2020)

Appeal from the denial of a juvenile offender's motion for sentence review under Rule 3.802 and section 921.1402. The Fifth District held the order erroneous for two reasons: it lacked the written findings required by section 921.1402(7) and Rule 3.802(d)(2), and the summary denial did not attach records conclusively refuting the claims. The court reversed, remanded for a sentence review, and directed that the review be conducted by a different judge.


Role: Appellate brief researched and drafted by Jabe Carney as a certified inmate law clerk for the pro se appellant.
Byrd v. State
182 So. 3d 889 (Fla. 1st DCA 2016)

Appeal from the summary denial of a pro se Rule 3.800(a) motion challenging a habitual-felony-offender enhancement on the ground that one predicate conviction was a misdemeanor, not a felony. The State conceded that the postconviction court had not conclusively refuted the claim. The First District reversed and remanded for the court to attach refuting records or resentence.


Role: Appellate brief researched and drafted by Jabe Carney as a certified inmate law clerk for the pro se appellant.

These descriptions summarize published opinions for background only. Past results do not predict or guarantee the outcome of any other matter. Every matter turns on its own record and law, and every filing Justice Insight prepares is reviewed and signed by supervising counsel, who remains responsible for it.

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