Sweet v. Canady

CourtDistrict Court, M.D. Florida
DecidedAugust 15, 2023
Docket3:22-cv-00574
StatusUnknown

This text of Sweet v. Canady (Sweet v. Canady) is published on Counsel Stack Legal Research, covering District Court, M.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sweet v. Canady, (M.D. Fla. 2023).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA JACKSONVILLE DIVISION

WILLIAM SWEET, KOSTANTINOS FOTOPOULOS, AND GLEN ROGERS,

Plaintiffs,

v. Case No. 3:22-cv-574-TJC-LLL

THE HONORABLE CARLOS G. MUÑIZ,

Defendant.

ORDER This § 1983 procedural due process action is before the Court on Defendant Chief Justice Carlos G. Muñiz’s Motion to Dismiss Plaintiffs’ Amended Verified Complaint. (Doc. 23). Plaintiffs William Sweet, Kostantinos Fotopoulos, and Glen Rogers jointly responded in opposition to the Motion. (Doc. 26). I. BACKGROUND1 Plaintiffs are three death-row inmates in the custody of the Florida Department of Corrections. (Doc. 19 ¶¶ 5–7). Plaintiffs are proceeding on a counseled Amended Complaint under 42 U.S.C. § 1983 against Chief Justice

1 These facts, assumed as true, are taken from the Amended Complaint. (Doc. 19). Carlos G. Muñiz in his official capacity as the Chief Justice of the Florida Supreme Court. Id. ¶ 5(g). Plaintiffs’ allegations stem from their dissatisfaction

with their representation by Capital Collateral Regional Counsel (CCRC) in their post-conviction proceedings and their inability under Florida law to file pro se claims regarding the effectiveness of CCRC. Id. ¶¶ 5(h), 6(h), 7(h). Representation by CCRC is governed by Chapter 27 of the Florida

Statutes. Id. ¶¶ 5(a), 6(a), 7(a). Plaintiffs allege that § 27.711(12), Florida Statutes, gives them “the assurance of ‘quality representation’ and monitoring of such performance.” Id. ¶¶ 5(j), 6(j), 7(j). Based on this entitlement to “quality representation,” Plaintiffs allege that the Florida Supreme Court has violated

Plaintiffs’ procedural due process rights by failing to “adopt a state-wide definition of ‘quality representation,’” failing to adopt “a mechanism for enforcement” to ensure “quality representation,” failing to provide “representation by counsel to address the failure of ‘quality representation,’”

barring Plaintiffs’ claims as “‘ineffective assistance’ of CCRC” claims, and barring Plaintiffs from “raising any of these issues pro se.” See generally id. Plaintiffs seek a declaratory judgment that § 27.711(12), Florida Statutes, “has created a liberty interest in procedural due process rights

requiring the Florida Supreme Court to define what constitutes ‘quality representation’ by CCRC,” a declaratory judgment that the Florida Supreme Court must establish procedures to evaluate the performance of CCRC, injunctive relief that would require the Florida Supreme Court to permit pro se death-row inmates to file claims under § 27.711(12), nominal damages, and a

writ of mandamus compelling the Florida Supreme Court to “establish a definition of ‘quality representation’ as required by the Florida legislature and to establish such rules of procedure to give meaningful effect to the legislative mandate.” Id. ¶ 9.

Chief Justice Muñiz argues that the Court should dismiss Plaintiffs’ claims because Plaintiffs lack standing to sue, their claims are barred by state sovereign immunity, they fail to state a claim for injunctive or declaratory relief, and federal courts do not have jurisdiction to issue writs of mandamus

compelling the Florida Supreme Court to perform a duty. See Doc. 23. II. LEGAL STANDARD A motion to dismiss brought under Federal Rule of Civil Procedure 12(b)(1) for lack of standing attacks the district court’s subject matter

jurisdiction. Article III, § 2 of the United States Constitution limits federal jurisdiction to actual cases or controversies. “The plaintiff has the burden to clearly and specifically set forth facts sufficient to satisfy Art. III standing requirements.” Bochese v. Town of Ponce Inlet, 405 F.3d 964, 976 (11th Cir.

2005) (quotation marks and citations omitted). To satisfy the “‘irreducible constitutional minimum’ of standing,” the “plaintiff must have (1) suffered an injury in fact, (2) that is fairly traceable to the challenged conduct of the defendant, and (3) that is likely to be redressed by a favorable judicial decision.” Spokeo, Inc. v. Robins, 578 U.S. 330, 338 (2016) (quoting Lujan v. Defs. of

Wildlife, 504 U.S. 555, 560 (1992)). “To establish injury in fact, a plaintiff must show that he or she suffered ‘an invasion of a legally protected interest’ that is ‘concrete and particularized’ and ‘actual or imminent, not conjectural or hypothetical.’” Id. at 339 (quoting

Lujan, 504 U.S. at 560). Additionally, when a plaintiff seeks prospective relief, he must “allege facts from which it appears there is a substantial likelihood that he will suffer injury in the future.” Mack v. USAA Cas. Ins. Co., 994 F.3d 1353, 1357 (11th Cir. 2021) (quoting Malowney v. Fed. Collection Deposit Grp., 193

F.3d 1342, 1346 (11th Cir. 1999)). “And that future injury must be ‘real,’ ‘immediate,’ and ‘definite.’” Id. (quoting Malowney, 193 F.3d at 1347). III. DISCUSSION Plaintiffs fail to establish an injury in fact because they have not alleged

an invasion of a legally protected interest. See Spokeo, 578 U.S. at 339. Plaintiffs allege that their legally protected interest arises from § 27.711(12), Florida Statutes. See generally Doc. 19. The statute provides: The court shall monitor the performance of assigned counsel to ensure that the capital defendant is receiving quality representation. The court shall also receive and evaluate allegations that are made regarding the performance of assigned counsel. The Justice Administrative Commission, the Department of Legal Affairs, or any interested person may advise the court of any circumstance that could affect the quality of representation, including, but not limited to, false or fraudulent billing, misconduct, failure to meet continuing legal education requirements, solicitation to receive compensation from the capital defendant, or failure to file appropriate motions in a timely manner. FLA. STAT. § 27.711(12). Section 27.7002(1), Florida Statues, provides that Chapter 27 of the Florida Statutes “does not create any right on behalf of any person, provided counsel pursuant to any provision of this chapter, to challenge in any form or manner the adequacy of the collateral representation provided.” FLA. STAT. § 27.7002(1). Nevertheless, Plaintiffs argue that “[w]hen state law mandates that a government body ensure a defendant is receiving quality

representation, a liberty interest in receiving quality representation is created warranting protection under the Due Process Clause of the Fourteenth Amendment.” (Doc. 26 at 5). However, the Supreme Court of the United States has refused to extend

a constitutional right to counsel to prisoners, including death-sentenced prisoners, mounting collateral attacks upon their convictions. See Pennsylvania v. Finley, 481 U.S. 551, 555 (1987); Murray v. Giarratano, 492 U.S. 1, 7–10 (1989) (plurality opinion). The Eleventh Circuit has held the same: “this court

has consistently held that there is no federal constitutional right to counsel in post[-]conviction proceedings.” Barbour v. Haley, 471 F.3d 1222, 1227 (11th Cir. 2006).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Malowney v. Federal Collection Deposit Group
193 F.3d 1342 (Eleventh Circuit, 1999)
Grayden v. Rhodes
345 F.3d 1225 (Eleventh Circuit, 2003)
Alfred L. Bochese v. Town of Ponce Inlet
405 F.3d 964 (Eleventh Circuit, 2005)
Christopher Barbour v. Michael Haley
471 F.3d 1222 (Eleventh Circuit, 2006)
Wainwright v. Torna
455 U.S. 586 (Supreme Court, 1982)
Evitts v. Lucey
469 U.S. 387 (Supreme Court, 1985)
Pennsylvania v. Finley
481 U.S. 551 (Supreme Court, 1987)
Murray v. Giarratano
492 U.S. 1 (Supreme Court, 1989)
Coleman v. Thompson
501 U.S. 722 (Supreme Court, 1991)
Lujan v. Defenders of Wildlife
504 U.S. 555 (Supreme Court, 1992)
Stojetz v. Ishee
389 F. Supp. 2d 858 (S.D. Ohio, 2005)
Spokeo, Inc. v. Robins
578 U.S. 330 (Supreme Court, 2016)
United States v. Delton Rushin
844 F.3d 933 (Eleventh Circuit, 2016)
Leroy Mack v. USAA Casualty Insurance Company
994 F.3d 1353 (Eleventh Circuit, 2021)

Cite This Page — Counsel Stack

Bluebook (online)
Sweet v. Canady, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sweet-v-canady-flmd-2023.