Michael Anthony Woods v. State of Florida
CourtDistrict Court of Appeal of Florida
Date FiledOctober 14, 2026
Docket3D2026-0286
StatusPublished
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Full Opinion
Third District Court of Appeal
State of Florida
Opinion filed October 14, 2026.
Not final until disposition of timely filed motion for rehearing.
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No. 3D26-0286
Lower Tribunal No. F17-9835
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Michael Anthony Woods,
Appellant,
vs.
State of Florida,
Appellee.
An Appeal under Florida Rule of Appellate Procedure 9.141(b)(2) from
the Circuit Court for Miami-Dade County, Milton Hirsch, Judge.
Michael Anthony Woods, in proper person.
James Uthmeier, Attorney General, and Daniel Colmenares and Jason
Michael Ross, Assistant Attorneys General, for appellee.
Before SCALES, C.J., and LOGUE and LOBREE, JJ.
PER CURIAM.
On the State’s Confession of Error
The record reflects that, in an October 24, 2025 order, the
postconviction court found appellant Michael Anthony Woods’s
postconviction motion facially insufficient and denied the motion without
prejudice to Woods filing an amended motion within sixty days. Woods, who
is incarcerated, filed his amended postconviction motion fifty-four days later,
on December 17, 2025, under the prisoner mailbox rule. See Haag v. State,
591 So. 2d 614, 617 (Fla. 1992) (“Under the mailbox rule, a petition or notice
of appeal filed by a pro se inmate is deemed filed at the moment in time when
the inmate loses control over the document by entrusting its further delivery
or processing to agents of the state. Usually, this point occurs when the
inmate places the document in the hands of prison officials.”). It appears that
Woods’s amended motion was not received by the trial court until January
5, 2026.
Because Woods’s amended postconviction motion was timely filed, the
trial court’s final orders of December 30, 2025, and January 20, 2026 (the
“Orders”), denying Woods’s respective motions must be reversed, and the
case be remanded with instructions for the postconviction court to adjudicate
Woods’s amended postconviction motion. See Simmons v. State, 293 So.
3d 604, 606 (Fla. 1st DCA 2020) (“Because the postconviction court had
unrebutted evidence that the appellant timely filed his motion for
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postconviction relief, it erred by failing to accept the filing as timely filed.
Accordingly, we reverse and remand for further proceedings.”); Loray v.
State, 80 So. 3d 428, 429 (Fla. 4th DCA 2012) (“Based on application of this
authority, and the State's response agreeing that the matter should be
remanded to the trial court, we reverse and remand for further consideration
of this motion for post-conviction relief.”).
Based on the State’s commendable confession of error, we reverse
the Orders and remand with instructions.
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