The Justice Administrative Commission v. Ian Jackson

CourtDistrict Court of Appeal of Florida
DecidedMay 13, 2026
Docket3D2022-2082
StatusPublished

This text of The Justice Administrative Commission v. Ian Jackson (The Justice Administrative Commission v. Ian Jackson) is published on Counsel Stack Legal Research, covering District Court of Appeal of Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
The Justice Administrative Commission v. Ian Jackson, (Fla. Ct. App. 2026).

Opinion

Third District Court of Appeal State of Florida

Opinion filed May 13, 2026. Not final until disposition of timely filed motion for rehearing.

________________

No. 3D22-2082 Lower Tribunal No. F20-9049 ________________

The Justice Administrative Commission, Petitioner,

vs.

Ian Jackson, Respondent.

A Writ of Certiorari to the Circuit Court for Miami-Dade County, Alberto Milian, Judge.

Ana Cristina Martinez, General Counsel and Christian D. Lake, Assistant General Counsel (Tallahassee), for petitioner.

Ana M. Davide, P.A., and Ana M. Davide, for respondent.

Michael T. Davis and Daniel Tibbitt for Florida Association of Criminal Defense Lawyers-Miami Chapter as amicus curiae.

Before FERNANDEZ, LINDSEY and LOBREE, JJ.

LOBREE, J. In this murder case in which the State has noticed its intent to seek the

death penalty, the Justice Administrative Commission (“JAC”) seeks a writ

of certiorari to quash the trial court’s order appointing private, second chair

co-counsel and ordering that it pay co-counsel’s attorney’s fees where the

defendant, Ian Jackson, is already represented by a privately retained

attorney. We grant the petition for writ of certiorari, quash the order under

review, and certify to the Florida Supreme Court a question of great public

importance.

BACKGROUND

In July 2020, Jackson was charged with one count of second-degree

murder with a firearm. He retained private counsel Ana Davide to represent

him on that charge for a specific fee amount. Soon thereafter, Jackson was

declared indigent for costs. Almost two years later, the State charged

Jackson by indictment with two counts of first-degree murder and filed its

notice of intent to seek the death penalty.

Jackson moved to appoint private attorney Reginald (Tony) Moss as

second chair, penalty phase counsel, stating that he did not have money to

retain a second attorney to handle the penalty phase of a death penalty case.

Jackson argued that his Sixth Amendment right to effective assistance of

counsel mandated Moss’s appointment, in part because he was unable to

2 afford two attorneys. Jackson maintained that failure to appoint Moss would

violate his rights to due process and equal protection under Florida and

Federal Constitutions.

JAC objected to Moss’s appointment, contending that section

27.52(5)(h), Florida Statutes, bars the appointment of a lawyer when a

defendant has privately retained and paid counsel. The Public Defender for

the Eleventh Judicial Circuit objected to its appointment as co-counsel,

arguing that under section 27.51(2), Florida Statutes (2021), it could not

represent Jackson because he was already represented by private counsel.

Similarly, the Office of Criminal Conflict and Civil Regional Counsel, Third

Region, objected to its appointment as co-counsel, contending that under

section 27.511(7), Florida Statutes (2022), it could not represent Jackson

where he had privately retained counsel.

After a hearing, the trial court entered a written order granting

Jackson’s motion, appointing Moss, and ordering that JAC “shall pay the

attorney fees, costs, and related expenses of Tony Moss.” Among other

things, the trial court found that Jackson lacked the funds to pay for a penalty

phase, second chair co-counsel, and that Jackson wished to maintain

Davide as his counsel. The trial court found that Moss’s appointment was

“necessary to protect [Jackson’s] rights and that he is entitled to a penalty

3 phase second chair co-counsel that can legally and ethically represent him

in this case.” Finally, the trial court determined that “this is a matter of great

public importance which will have a great impact upon the administration of

justice throughout the State of Florida requiring immediate resolution by the

Third District Court of Appeal as well as the Florida Supreme Court.”

(emphasis in original).

ANALYSIS

To obtain a writ of certiorari, JAC must show that the trial court’s order

appointing Moss as co-counsel and ordering it to pay attorney’s fees, costs,

and expenses related to Moss1 “constitutes (1) a departure from the essential

requirements of the law, (2) resulting in material injury for the remainder of

the case, (3) that cannot be corrected on post-judgment appeal.” Damsky v.

Univ. of Miami, 152 So. 3d 789, 792 (Fla. 3d DCA 2014). Together, the

second and third prongs are referred to as “irreparable harm,” and “[t]he

irreparable-harm inquiry . . . presents a threshold jurisdictional issue to be

decided before determining if a departure from the essential requirements of

law has occurred.” Vericker v. Powell, 406 So. 3d 939, 943–44 (Fla. 2025).

We find that the threshold showing of irreparable harm is met here because

1 Upon final disposition of the case, Moss would be entitled to a flat fee for his representation as set forth in section 27.5304(1)–(5), Florida Statutes (2022).

4 a Florida state agency, such as JAC, suffers a material injury where a trial

court’s order “interfere[s] with [the agency]’s responsibility to expend its

appropriated funds in accordance with the laws governing [that agency],”

Dep’t of Child. & Fams. v. Lotton, 172 So. 3d 983, 988 (Fla. 5th DCA 2015),

and JAC has “no adequate remedy on appeal considering [its] non-party

status,” Dep’t of Child. & Fams. v. Garcia, 245 So. 3d 919, 922 (Fla. 3d DCA

2018) (quoting State Dep’t of Health & Rehab. Servs. v. Myers, 696 So. 2d

863, 865 (Fla. 4th DCA 1997)). See also Just. Admin. Comm’n v. Wahid,

390 So. 3d 705, 710 (Fla. 3d DCA 2024) (“A petition for writ of certiorari is

the proper vehicle for reviewing an order concerning attorney’s fees for

private court-appointed counsel.”).

Turning to the merits, a departure from the essential requirements of

the law occurs “where there has been a violation of a clearly established

principle of law.” Citizens Prop. Ins. Corp. v. San Perdido Ass’n, Inc., 104

So. 3d 344, 355 (Fla. 2012). “Clearly established law ‘can derive from a

variety of legal sources, including recent controlling case law, rules of court,

statutes, and constitutional law.’” Rosich-Medina v. Chilaud, 426 So. 3d 578,

581 (Fla. 3d DCA 2025) (quoting Allstate Ins. Co. v. Kaklamanos, 843 So.

2d 885, 890 (Fla. 2003)).

JAC argues that the trial court departed from the essential

5 requirements of law in appointing a private attorney to serve as co-counsel

where Jackson is represented by a privately retained and paid attorney.

Specifically, JAC argues that Moss’s appointment is contrary to the plain

language of section 27.52(5)(h), Florida Statutes (2022), which provides as

follows: “The court may not appoint an attorney paid by the state based on a

finding that the defendant is indigent for costs if the defendant has privately

retained and paid counsel.” Jackson responds that the trial court did not

depart from the essential requirements of law in appointing Moss because

section 27.51(2), Florida Statutes (2022), permits the trial court to appoint

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