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William Faiella v. State

Citations: 203 So. 3d 199; 2016 Fla. App. LEXIS 16564Docket: 5D16-2446

Court: District Court of Appeal of Florida; October 31, 2016; Florida; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

The case involves an appeal by a defendant, William Faiella, challenging the denial of his motion for post-conviction relief under Florida Rule of Criminal Procedure 3.850. The appeal focused on several grounds, specifically addressing the claim of ineffective assistance of counsel. Faiella argued that his attorney misinformed him about the applicability of Florida's Civil Commitment of Sexually Violent Predators Act, known as the Jimmy Ryce Act, suggesting he was not subject to it. The post-conviction court dismissed this claim, reasoning that civil commitment is a collateral consequence and does not require advisement by counsel. However, the appellate court found this dismissal erroneous, citing a precedent that supports claims of affirmative misadvice concerning the Jimmy Ryce Act. It further emphasized that the presence of civil commitment language in the plea agreement does not invalidate Faiella's claim. As a result, the appellate court reversed the denial of the ineffective assistance of counsel claim, remanding the case for an evidentiary hearing or for the post-conviction court to provide records that conclusively refute the claim. All other grounds in the appeal were affirmed by the appellate court.

Legal Issues Addressed

Affirmative Misadvice and the Jimmy Ryce Act

Application: The appellate court referenced a precedent that supports claims of affirmative misadvice relating to the Jimmy Ryce Act, indicating that incorrect advisement can be grounds for relief.

Reasoning: The appellate court found this ruling erroneous, referencing a precedent that supports claims of affirmative misadvice regarding the Jimmy Ryce Act.

Collateral Consequences of Pleas

Application: The post-conviction court initially held that counsel was not obligated to advise Faiella on the civil commitment as it is a collateral consequence of a plea.

Reasoning: The post-conviction court dismissed this claim, stating that civil commitment is a collateral consequence of a plea and that counsel was not obligated to advise on it.

Impact of Plea Agreement Language on Misadvice Claims

Application: The court noted that language in the plea agreement regarding civil commitment does not negate the claim of misadvice.

Reasoning: Furthermore, the court noted that a paragraph in the plea agreement addressing civil commitment does not negate Faiella's claim.

Ineffective Assistance of Counsel in Plea Agreements

Application: The appellate court determined that the post-conviction court erred in dismissing the claim of ineffective assistance of counsel regarding misadvice about the applicability of the Jimmy Ryce Act.

Reasoning: Faiella contends his defense attorney incorrectly informed him that he was not subject to Florida's Civil Commitment of Sexually Violent Predators Act (Jimmy Ryce Act), which may not have been accurate.