Joseph Wainwright v. State of Florida
CourtDistrict Court of Appeal of Florida
Date FiledSeptember 9, 2026
Docket1D2025-1880
StatusPublished
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Full Opinion
FIRST DISTRICT COURT OF APPEAL
STATE OF FLORIDA
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No. 1D2025-1880
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JOSEPH WAINWRIGHT,
Appellant,
v.
STATE OF FLORIDA,
Appellee.
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On appeal from the Circuit Court for Suwannee County.
Mark E. Feagle, Judge.
September 9, 2026
PER CURIAM.
Joseph Wainwright appeals a final order denying his motion
for postconviction relief under Florida Rule of Criminal Procedure
3.850. The postconviction court held an evidentiary hearing on
grounds two and eight and summarily denied the remaining
grounds. We affirm except as to a subclaim of ground four.
A jury convicted Wainwright of trafficking in
methamphetamine and possession of a firearm or ammunition by
a convicted felon. The State’s theory was that he knew of and
controlled methamphetamine and firearms found at the property
he shared with Ashley Hancock. The defense theory was that
Hancock, not Wainwright, controlled the safes, firearms, and
contraband.
We review de novo the summary denial of the claims
addressed in this opinion and accept the motion’s factual
allegations as true unless the record conclusively refutes them.
Foster v. State, 810 So. 2d 910, 914 (Fla. 2002). A facially sufficient
claim of ineffective assistance must allege deficient performance
and resulting prejudice. Strickland v. Washington, 466 U.S. 668,
687, 694 (1984). We independently analyze each distinct subclaim
to determine whether the allegations, accepted as true, establish
both elements and whether the record conclusively refutes relief.
When the record conclusively refutes relief, the final order’s failure
to separately analyze the theory does not require remand. Mejia v.
State, 434 So. 3d 131, 141 (Fla. 2d DCA 2026) (“We do hold,
however, that a postconviction court is not automatically subject
to reversal when it fails to expressly address a claim, provided the
order’s targeted attachments nonetheless permit meaningful
appellate review and conclusively refute the omitted claim.”).
When a timely motion contains both sufficient and insufficient
claims, rule 3.850(h)(3) governs the amendment procedure.
Ground one challenged counsel’s handling of a continuance
and counsel’s failure to object to witnesses and prospective jurors
wearing masks. We affirm the continuance ruling without further
discussion. The juror and witness components of the mask-
objection subclaim require separate analysis, and we affirm as to
both. As to prospective and seated jurors, the Confrontation Clause
does not apply because jurors are not witnesses, and courts have
rejected ineffective-assistance claims based on counsel’s failure to
object to pandemic masking during voir dire and trial. See United
States v. Ayala-Vieyra, No. 21-1177, 2022 WL 190756, at *5 (6th
Cir. Jan. 21, 2022); People v. Molina, 96 Cal. App. 5th 516, 520–21,
314 Cal. Rptr. 3d 465, 468–69 (2023). Counsel is not ineffective for
failing to make a meritless objection. Hitchcock v. State, 991 So. 2d
337, 361 (Fla. 2008).
The witness component presents a different question. Any
departure from face-to-face confrontation ordinarily requires a
case-specific finding of necessity. See Pitts v. Mississippi, 607 U.S.
1, 2, 5 (2025). But a masking claim still fails absent a
particularized showing of prejudice. See United States v. Shelton,
179 F.4th 1020, 1036–38 (6th Cir. 2026). We need not decide
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whether counsel performed deficiently because the record
conclusively refutes prejudice. Wainwright did not identify any
particular masked witness, credibility issue, obscured demeanor
cue, examination decision, or other concrete connection between
masking and the verdict. His generalized allegations would not
overcome the controlled call, Depremio’s testimony, the firearms
and methamphetamine found in a safe containing Wainwright’s
passport and mail, or the additional firearms and ammunition
found beneath the mattress and bed in the shared bedroom. Thus,
there is no reasonable probability that an objection to witness
masking would have changed the verdict.
Ground three alleged that counsel failed to impeach State
witness Melanie Depremio with deposition statements that the
firearms were for Hancock and that Hancock handled them.
Although the final order addressed other impeachment theories
without separately analyzing this one, the record conclusively
refutes prejudice. The deposition statements would still have
shown that Wainwright bought the firearms for Hancock. They did
not negate his possession of the firearms before or while
purchasing them for someone else. The jury also heard the defense
theory that Hancock controlled the safes and firearm locations.
Because the proposed impeachment was partly cumulative and did
not exculpate Wainwright on possession, there is no reasonable
probability that it would have changed the verdict.
Ground four alleged both a failure to object to Depremio’s
testimony about an alleged telephone call between Wainwright
and Corey Robinson and a failure to obtain evidence that
Wainwright claimed would show the call did not occur. We affirm
the failure-to-object subclaim for the reasons explained in the
postconviction court’s order. The distinct failure-to-obtain-
evidence subclaim, however, was not separately analyzed and is
legally insufficient as pleaded. Wainwright identified phones and
categories of possible data—call logs, memory data, and cell-tower
information—but did not allege what specific evidence existed,
whether counsel could have obtained it, or how it would have
disproved the alleged call.
Because Wainwright timely filed his motion, the motion
sufficiently stated other claims, and the postconviction court did
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not give him an opportunity to amend this insufficient subclaim,
rule 3.850(h)(3) required a nonappealable order granting sixty
days to amend. Spera v. State, 971 So. 2d 754, 761–62 (Fla. 2007).
We therefore reverse only this portion of ground four and remand
for the required amendment order.
In ground seven, Wainwright alleged that counsel misadvised
him that his criminal record would be exposed if he testified. The
trial colloquy establishes that he voluntarily chose not to testify,
but it does not reveal or conclusively refute the alleged legal advice
that led to that choice. Askew v. State, 265 So. 3d 693, 694 (Fla. 1st
DCA 2019). That does not end the analysis because Wainwright
must independently establish prejudice. See Rizkkhalil v. State,
316 So. 3d 802, 805–06 (Fla. 1st DCA 2021). Even accepting the
alleged misadvice as true, the record conclusively refutes
prejudice. Wainwright’s proposed testimony denying the Robinson
call, gun purchase, access, dominion, and control, and attributing
the contraband to Hancock would have repeated the defense
theory presented at trial. Against the controlled call, Depremio’s
testimony, the firearms and methamphetamine found in a safe
containing Wainwright’s passport and mail, and the additional
firearms and ammunition found beneath the mattress and bed in
the shared bedroom, the proposed testimony does not create a
reasonable probability of a different verdict. Id. at 806.
We affirm all other portions of the order without further
discussion, including the denial of cumulative relief. The limited
remand provides only an opportunity to amend the subclaim in
ground four.
AFFIRMED in part; REVERSED in part; and REMANDED.
OSTERHAUS, C.J., and BILBREY and NEFF, JJ., concur.
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Not final until disposition of any timely and
authorized motion under Fla. R. App. P. 9.330 or
9.331.
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Deana K. Marshall of Law Office of Deana K. Marshall, P.A.,
Riverview, for Appellant.
James Uthmeier, Attorney General, and Julian E. Markham,
Assistant Attorney General, Tallahassee, for Appellee.
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