Services
Florida postconviction and appellate work, built from the record up.
Every assignment starts with the record and ends with a draft you can review, revise, and sign. Florida state-court work is the core of it. Federal and administrative support is available on the same attorney-directed terms.
Postconviction cases are won or lost in the record.
A facially sufficient 3.850 claim needs record citations, attachments, and a prejudice argument tied to specific testimony. A 3.800(a) claim turns on what the record shows on its face. An appellate issue depends on what was preserved below.
That means reading all of it first: the transcripts, the plea colloquy, the scoresheet, the prior orders and opinions. It is the part of this work most practices cannot staff, and it is the part Justice Insight is built to do.
Florida state courts
From the first look at the record to the reply brief.
Postconviction
Record review & issue assessment
A written memo on what the record supports: cognizable claims, preservation, time limits, and the procedural barriers, for your evaluation. Often the right first step before any motion.
Rule 3.850 motions
Ineffective-assistance, involuntary-plea, and newly discovered evidence claims drafted to the applicable pleading requirements, with record citations, attachments, and the oath. Amended motions after a Spera order.
Rule 3.800(a) and 3.800(b) motions
Illegal sentences, scoresheet errors, habitual-offender and PRR enhancement defects, and jail credit. Rule 3.800(b)(2) motions to preserve sentencing error while an appeal is pending.
Juvenile sentence review
Resentencing under section 921.1401 after Miller and Graham, and Rule 3.802 applications for sentence review under section 921.1402, with the supporting rehabilitation and mitigation record.
Appeals
Direct appeals
Initial and reply briefs in all six District Courts of Appeal, including large-record, multi-issue appeals. Motions to supplement the record and to relinquish jurisdiction as needed.
Postconviction appeals
Briefs from summary denials under Rule 9.141(b)(2) and from orders entered after an evidentiary hearing under Rule 9.141(b)(3).
Florida Supreme Court
Jurisdictional briefs and merits briefs on discretionary review.
Rehearing & en banc
Motions for rehearing, clarification, written opinion, certification, and rehearing en banc under Rules 9.330 and 9.331.
Writs & hearings
Extraordinary writs
Petitions for belated appeal under Rule 9.141(c), habeas petitions alleging ineffective assistance of appellate counsel, mandamus, and prohibition, with appendices.
Evidentiary hearing preparation
Hearing memoranda, exhibit sets, witness examination outlines, subpoenas, and proposed orders. Resentencing and mitigation packages.
Also available
Federal & administrative support
Section 2254 petitions
Timeliness and exhaustion analysis, record review, petitions, and replies to the State's response.
Section 1983 litigation support
Attorney-directed research and drafting for civil-rights litigation arising from custody.
Federal-court mechanics
PACER docket research and retrieval, case organization, and preparation of summons and service materials under counsel's direction.
FDC administrative remedies
Grievances, appeals, and exhaustion analysis, with research into corrections procedure.
Record review
What gets looked for.
The claims assessed on a first pass through a record. Not every matter supports every theory; the memo says which ones the record will carry and which it will not.
Trial counsel
Investigation and witnesses
Failure to investigate, locate, depose, or call a witness whose testimony the record shows was available.
Plea advice
An Alcorn claim: a rejected or unconveyed offer, misadvice on exposure, and the pleading elements the claim has to meet to survive summary denial.
Suppression
Motions not filed or not pressed — four-corners challenges to a warrant affidavit, standing, consent, and the scope of a search.
Preservation and objection
Failure to object, move for mistrial, or renew; failure to request a Richardson hearing; cumulative error where no single omission carries the claim.
The State
Disclosure
Brady material suppressed or produced late, and Giglio claims where testimony the State relied on was false or left uncorrected.
Argument and evidence
Improper comment, burden-shifting, and the preservation posture that determines whether the issue is reviewable or fundamental.
Plea and sentence
Involuntary plea
Colloquy defects, misadvice on maximum exposure or collateral consequences, and habitualization where the State’s written notice of intent came after the plea rather than before it, as Ashley requires.
Sentencing error
Illegal sentences, scoresheet error, and defects in PRR, HFO, and HVFO designations — including whether the finding was one a jury had to make.
Juvenile sentencing
Resentencing under section 921.1401, where the court weighs the offense and the offender as he was. Sentence review under section 921.1402, on a Rule 3.802 application, where Murphy puts the focus on the present — rehabilitation and fitness to reenter society.
Getting past the gate
Timeliness
The two-year window and the Rule 3.850(b)(2) exception for a right established later and held retroactive — pleaded to its terms, not assumed.
Successiveness and bar
Whether a claim was raised, could have been raised, or is barred, and where manifest injustice or an intervening decision changes that.
Newly discovered evidence
Due diligence, the recanting witness problem, and whether the evidence satisfies Jones — unknown at trial and not discoverable by diligence, and of a weight that would probably produce an acquittal on retrial.
Standard of review
On appeal, what was preserved, what is fundamental, and which standard the issue actually draws.
Every draft
What arrives with the work.
Record citations
Every factual assertion cited to the record by page.
Current authority
Every case checked for subsequent history before delivery.
Rule-compliant format
Font, word count, and certificates under Rules 9.045 and 9.210, or the circuit's requirements for a trial-court filing.
A cover memo
What the draft argues, what it leaves out and why, and the judgment calls left for you.
How engagements work
Conflict check first
Before any confidential material changes hands.
Record review is a paid first step
Record review carries a flat fee of its own, credited in full against the project fee if you proceed. The project fee is quoted once the record has been reviewed, so the budget is set before drafting begins.
Record work billed separately
Supplementation, relinquishment, and unsealing are billed hourly, outside the flat fee, because their scope cannot be known in advance.
Filing support when you want it
Portal filing and service through your firm's own account, when you authorize it. You remain responsible for review, signature, and filing authority.
Rush work by agreement
Short deadlines are accepted when the schedule allows, on terms agreed in advance.
Justice Insight does not
Appear as counsel or sign a pleading
File except through your own filing account, at your direction
Provide legal advice to your client. Any client contact is factual or administrative only, and only at your direction
Accept work from anyone other than a licensed attorney
Not sure which service fits?
Describe the matter and the deadline. A record review is often the right place to start. You'll hear back within one business day.