Michael Lawrence Woodbury v. State of Florida & Michael Lawrence Woodbury v. Secretary, Department of Corrections

CourtSupreme Court of Florida
DecidedJune 11, 2026
DocketSC2024-0232 & SC2024-1127
StatusPublished

This text of Michael Lawrence Woodbury v. State of Florida & Michael Lawrence Woodbury v. Secretary, Department of Corrections (Michael Lawrence Woodbury v. State of Florida & Michael Lawrence Woodbury v. Secretary, Department of Corrections) is published on Counsel Stack Legal Research, covering Supreme Court of Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Michael Lawrence Woodbury v. State of Florida & Michael Lawrence Woodbury v. Secretary, Department of Corrections, (Fla. 2026).

Opinion

Supreme Court of Florida ____________

No. SC2024-0232 ____________

MICHAEL LAWRENCE WOODBURY, Appellant,

vs.

STATE OF FLORIDA, Appellee.

____________

No. SC2024-1127 ____________

MICHAEL LAWRENCE WOODBURY, Petitioner,

SECRETARY, DEPARTMENT OF CORRECTIONS, Respondent.

June 11, 2026

PER CURIAM.

Michael Lawrence Woodbury, a prisoner under a sentence of

death, appeals the circuit court’s denial of his initial motion for

postconviction relief under Florida Rule of Criminal Procedure 3.851 and petitions this Court for a writ of habeas corpus. We have

jurisdiction. See art. V, § 3(b)(1), (9), Fla. Const. For the reasons

that follow, we affirm the denial of postconviction relief and deny

Woodbury’s petition.

I.

A.

Woodbury, while serving life sentences for killing three people,

murdered his cellmate. Woodbury v. State, 320 So. 3d 631, 638

(Fla. 2021). He did so by barricading the door to his cell and then

brutalizing his cellmate for hours with makeshift weapons. Id. At

his first court appearance, Woodbury invoked his right to represent

himself and underwent a Faretta 1 inquiry. Woodbury, 320 So. 3d at

638. Woodbury remained steadfast in his decision to waive

counsel, continually stating that he understood the disadvantages

he was to face and expressing frustration with the repeated Faretta

inquiries. Id. at 638-41. He later declined to present mitigation,

pled guilty to first-degree murder, and was sentenced to death. Id.

at 641-43.

1. Faretta v. California, 422 U.S. 806 (1975).

-2- We affirmed Woodbury’s conviction and sentence on direct

appeal.2 Id. at 643. He then sought review by the United States

Supreme Court via a petition for writ of certiorari, which it denied.

Woodbury v. Florida, 142 S. Ct. 1135 (2022).

B.

Woodbury timely filed a motion to vacate judgment of

conviction and sentence pursuant to Florida Rule of Criminal

2. Woodbury presented eleven claims of error arguing that the trial court erred by: (1) granting Woodbury’s waiver of counsel and request to proceed pro se without first ordering a mental health evaluation; (2) failing to sua sponte order a competency hearing to determine if Woodbury was competent to stand trial; (3) accepting a guilty plea that was not entered intelligently and voluntarily and had no factual basis; (4) failing to renew the offer of counsel at the start of the defense case-in-chief and when Woodbury announced his change of plea; (5) accepting Woodbury’s waiver of mental health mitigation without appointing special counsel to present mitigation evidence; (6) finding that the murder was committed in a cold, calculated, and premeditated manner, and instructing the jury on that aggravator; (7) admitting a noncomprehensive presentence investigation report that contained impermissible sentencing recommendations; (8) assigning minimal weight to the mitigator of extreme mental or emotional disturbance; (9) rejecting a requested special jury instruction on mercy; and (10) failing to instruct the jury that it must find beyond a reasonable doubt that the aggravators outweighed the mitigators and were sufficient for the death penalty. Woodbury, 320 So. 3d at 643. The eleventh claim was a request for proportionality review which we declined to address in light of our decision in Lawrence v. State, 308 So. 3d 544 (Fla. 2020). Woodbury, 320 So. 3d at 643 n.3.

-3- Procedure 3.851, seeking to vacate his conviction and sentence on

seven grounds. 3 The circuit court held a Huff 4 hearing and

summarily denied all seven claims. Woodbury appeals and has also

filed a petition for writ of habeas corpus raising two claims.5

II.

In reviewing a summary denial of an initial 3.851 motion, we

affirm “if the filings show that the movant has failed to state a

facially sufficient claim, there is no issue of material fact to be

3. Woodbury argued: (1) his death sentence violates the Eighth Amendment because of his mental illness; (2) the trial court unconstitutionally encouraged him to wear shackles and prison clothes; (3) he was incompetent and should not have been allowed to proceed pro se; (4) he was affirmatively misled during his Faretta inquiries; (5) standby counsel rendered ineffective assistance by failing to call witnesses, obtain mental health records, and advise the court-appointed expert about his mental health status; (6) the State violated Brady v. Maryland by failing to turn over mental health records; and (7) he is insane and cannot be executed.

4. Huff v. State, 622 So. 2d 982 (Fla. 1993).

5. Woodbury argues in his petition that (1) appellate counsel on direct appeal was ineffective for failing to raise the claim that Woodbury was unconstitutionally forced to wear shackles and prison garb and (2) appellate counsel was ineffective for failing to raise the claim that Woodbury was misled during the Faretta inquiries.

-4- determined, the claim should have been brought on direct appeal,

or the claim is positively refuted by the record.” Kocaker v. State,

311 So. 3d 814, 821 (Fla. 2020) (quoting Barnes v. State, 124 So. 3d

904, 911 (Fla. 2013)). As to those claims that could have been

raised on direct appeal, we have said that they are procedurally

barred because such claims “are not cognizable through collateral

attack” and “are precluded from our consideration by collateral

review.” Smith v. State, 445 So. 2d 323, 325 (Fla. 1983). Our

review is de novo. Kocaker, 311 So. 3d at 821.

Woodbury presents seven issues for our consideration. He

concedes that his insanity claim is not ripe for our review, so we do

not address it. As to the remaining six claims, we conclude none

demonstrate error.

To start, Woodbury argues that the circuit court erred when it

summarily denied his claim that the State committed Brady6 and

Giglio7 violations. However, his postconviction motion frames the

6. Brady v. Maryland, 373 U.S. 83 (1963).

7. Giglio v. United States, 405 U.S. 150 (1972).

-5- issue only as a Brady violation. For that reason, any claim based

on Giglio is unpreserved for appeal and cannot serve as a basis for

relief. See Wickham v. State, 124 So. 3d 841, 853 (Fla. 2013)

(holding that a failure to raise a Giglio claim in a postconviction

motion renders the argument unpreserved for appellate review).

As to the alleged Brady violation, the postconviction court

properly denied Woodbury’s claim. The Brady rule only applies to

“the discovery, after trial, of information which had been known to

the prosecution but unknown to the defense.” Rhodes v. State, 986

So. 2d 501, 507 (Fla. 2008) (quoting United States v. Agurs, 427

U.S. 97, 103 (1976)). As a result, courts have denied postconviction

relief based on alleged Brady violations where the motion failed to

demonstrate the relevant information was unavailable to the

defense. For example, in Owen v. State, 986 So. 2d 534, 547 (Fla.

2008), we held that a postconviction motion alleging a Brady claim

was insufficiently pled where the claim was based on the

defendant’s therapist’s notes, his motion did not explain how he

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Related

Brady v. Maryland
373 U.S. 83 (Supreme Court, 1963)
Giglio v. United States
405 U.S. 150 (Supreme Court, 1972)
Faretta v. California
422 U.S. 806 (Supreme Court, 1975)
United States v. Agurs
427 U.S. 97 (Supreme Court, 1976)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Deck v. Missouri
544 U.S. 622 (Supreme Court, 2005)
Bryant v. State
785 So. 2d 422 (Supreme Court of Florida, 2001)
Farina v. State
937 So. 2d 612 (Supreme Court of Florida, 2006)
Williamson v. Dugger
651 So. 2d 84 (Supreme Court of Florida, 1994)
Johnson v. Moore
837 So. 2d 343 (Supreme Court of Florida, 2002)
Huff v. State
622 So. 2d 982 (Supreme Court of Florida, 1993)
McKenzie v. State
29 So. 3d 272 (Supreme Court of Florida, 2010)
Demps v. State
416 So. 2d 808 (Supreme Court of Florida, 1982)
Smith v. State
445 So. 2d 323 (Supreme Court of Florida, 1983)
Sireci v. State
773 So. 2d 34 (Supreme Court of Florida, 2000)
Castor v. State
365 So. 2d 701 (Supreme Court of Florida, 1978)
Rutherford v. Moore
774 So. 2d 637 (Supreme Court of Florida, 2000)
Behr v. Bell
665 So. 2d 1055 (Supreme Court of Florida, 1996)
Stueber v. Gallagher
812 So. 2d 454 (District Court of Appeal of Florida, 2002)
Jones v. State
949 So. 2d 1021 (Supreme Court of Florida, 2006)

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