A Florida appellate court on Wednesday affirmed the dismissal of a habeas corpus petition filed by an inmate challenging his life sentence, ruling that the legal challenge was brought in the wrong judicial circuit.
The Third District Court of Appeal ruled that neither it nor the Miami-Dade Circuit Court had the legal authority to address the post-conviction claims raised by Roland Morales.
Morales, who represented himself in the appeal, asked the court to set aside his life sentence and sentencing enhancements. He argued that his trial counsel provided ineffective assistance, operated under a conflict of interest, and that his enhanced sentence violated the U.S. Supreme Court’s 2024 precedent in Erlinger v. United States.
Although Morales titled his filing as a petition for writ of habeas corpus, the court determined that the filing was functionally a Rule 3.850 post-conviction motion targeting the legality of his trial and sentence.
Because Morales was originally convicted and sentenced in the Thirteenth Judicial Circuit—which encompasses Hillsborough County—the court held that his post-conviction claims must be filed in that jurisdiction rather than the circuit where he is currently held.
“[W]hen the petition is based upon the legality of the conviction imposed in another circuit, jurisdiction lies in the circuit that imposed the sentence, not the circuit where the petitioner is incarcerated,” the panel wrote, citing its 2007 decision in Johnson v. State.
The per curiam opinion was issued by Judges Logue, Lindsey, and Lobree. Circuit Judge Laura María González-Marqués presided over the underlying trial court decision in Miami-Dade County. Florida Attorney General James Uthmeier represented the state.
The court affirmed the trial court’s denial without prejudice, allowing Morales leave to refile his claims in the Thirteenth Judicial Circuit.
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