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Viera v. State

Citations: 133 So. 3d 563; 2014 Fla. App. LEXIS 1822; 2014 WL 539847Docket: No. 2D11-4093

Court: District Court of Appeal of Florida; February 11, 2014; Florida; State Appellate Court

Narrative Opinion Summary

Carlos Viera filed a petition under Florida Rule of Appellate Procedure 9.141(d), claiming ineffective assistance of appellate counsel for failing to argue that the jury instruction on manslaughter by act used during his second-degree murder trial constituted fundamental error. Referencing the precedent set in Horne v. State, 128 So.3d 953 (Fla. 2d DCA 2013), the court determined that the argument had merit. Consequently, the court reversed Viera's second-degree murder conviction and remanded the case for a new trial. Judges Casanueva, Morris, and Black concurred with the decision.

Legal Issues Addressed

Fundamental Error in Jury Instructions

Application: The court determined that the use of a flawed jury instruction on manslaughter by act during the trial constituted a fundamental error, warranting the reversal of the conviction.

Reasoning: Referencing the precedent set in Horne v. State, 128 So.3d 953 (Fla. 2d DCA 2013), the court determined that the argument had merit.

Ineffective Assistance of Appellate Counsel

Application: The court assessed a claim of ineffective assistance of appellate counsel based on the failure to argue a fundamental jury instruction error and found the claim to be meritorious.

Reasoning: Carlos Viera filed a petition under Florida Rule of Appellate Procedure 9.141(d), claiming ineffective assistance of appellate counsel for failing to argue that the jury instruction on manslaughter by act used during his second-degree murder trial constituted fundamental error.

Reversal of Conviction and Remand for New Trial

Application: Due to the recognized fundamental error in the jury instructions, the court reversed the second-degree murder conviction and ordered a new trial.

Reasoning: Consequently, the court reversed Viera's second-degree murder conviction and remanded the case for a new trial.