Ahmad Milton v. State of Florida

Summary

The Third District Court of Appeal of Florida affirmed the denial of Ahmad Milton’s motion for post-conviction relief under Florida Rule of Criminal Procedure 3.850. The court held that the employment records were known to or equally accessible by the defense and prosecution, so they did not constitute newly discovered evidence and their nondisclosure did not establish a Brady violation.

Holdings

1. The employment records did not constitute newly discovered evidence because they were known to Milton and his attorney at trial and were equally accessible to the defense and prosecution.
2. There was no Brady violation because the records were known to Milton and his attorney and were equally accessible to the defense and prosecution.
3. Milton was not entitled to relief on his ineffective-assistance allegation concerning counsel's failure to seek the employment records.
4. The trial court properly summarily denied Milton's motion for reconsideration and to compel the alleged newly discovered Brady material.

Questions Presented

1. Whether the employment records qualified as newly discovered evidence warranting post-conviction relief under Florida Rule of Criminal Procedure 3.850.
2. Whether the State violated Brady v. Maryland by failing to disclose the employment records.
3. Whether Milton was entitled to relief based on ineffective assistance of counsel for failing to seek the records.
4. Whether the trial court properly summarily denied Milton's motion for reconsideration and to compel the alleged newly discovered Brady material.

Disposition

affirmed