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OFFICE OF THE PUBLIC DEFENDER v. Madison

Citations: 961 So. 2d 1044; 2007 WL 2065836Docket: 1D06-1746

Court: District Court of Appeal of Florida; July 20, 2007; Florida; State Appellate Court

Narrative Opinion Summary

Once the Office of the Public Defender's representation of an indigent defendant concludes, it is required to surrender any trial transcripts in its possession to the defendant upon request. This obligation is supported by case law, including Pearce v. Sheffey, which mandates the relinquishment of transcripts at the conclusion of an appeal, and Thompson v. Unterberger, which confirms a petitioner's entitlement to such transcripts. Mandamus is deemed an appropriate remedy to compel the public defender to provide transcripts after representation has ended. However, the court clarifies that while the public defender is obligated to provide transcripts post-representation, there is no duty to do so while still representing the defendant on direct appeal. Consequently, the trial court's grant of mandamus in this case is reversed. Judges Kahn, Lewis, and Hawkes concur in the decision.

Legal Issues Addressed

Mandamus as Remedy for Transcript Provision

Application: Mandamus is an appropriate legal remedy to compel the public defender to provide transcripts after their representation has ended.

Reasoning: Mandamus is deemed an appropriate remedy to compel the public defender to provide transcripts after representation has ended.

No Duty to Provide Transcripts During Direct Appeal

Application: The public defender is not obligated to provide trial transcripts to the defendant while still representing them on direct appeal.

Reasoning: The court clarifies that while the public defender is obligated to provide transcripts post-representation, there is no duty to do so while still representing the defendant on direct appeal.

Obligation to Surrender Trial Transcripts

Application: The Office of the Public Defender must provide trial transcripts to an indigent defendant upon request after the conclusion of representation.

Reasoning: Once the Office of the Public Defender's representation of an indigent defendant concludes, it is required to surrender any trial transcripts in its possession to the defendant upon request.

Reversal of Mandamus Grant

Application: The trial court's decision to grant mandamus compelling the public defender to provide transcripts was reversed.

Reasoning: Consequently, the trial court's grant of mandamus in this case is reversed.