discussed Cited as authority (rule) Henry Martin Steiger v. State of Florida (2×) also: Cited "see, e.g." Kruse v. State, 222 So. 3d 13, 17 (Fla. 4th DCA 2017). - 15 - Jared Brown of Brown Legal PLLC, Fort Lauderdale, Florida; and Martin Roth of Martin L.

discussed Cited as authority (rule) EDDIE LARRY HOLLAND v. STATE OF FLORIDA Ineffective Assistance of Counsel “Ineffective assistance of counsel claims should rarely be raised on direct appeal because they are generally fact-specific . . . .” Kruse v. State, 222 So. 3d 13, 16 (Fla. 4th DCA 2017) (quoting Michel v. State, 989 So. 2d 679, 681 (Fla. 4th DCA 2008)). “[A]s a result, appellate courts do not usually address such claims ‘until a defendant seeks postconviction relief because such courts are limited to reviewing the record directly before them.’” Id. (quoting Monroe v. State, 191 So. 3d 395, 403 (Fla. 2016)).

discussed Cited as authority (rule) TAKENDRICK CAMPBELL v. STATE OF FLORIDA See State v. Plummer, 228 So. 3d 661, 668 (Fla. 1st DCA 2017) (concluding that counsel performed deficiently by failing to present evidence as to the nature of the gun—BB or airsoft—where the defendant was charged with carrying a weapon); Kruse v. State, 222 So. 3d 13, 17 (Fla. 4th DCA 2017) (concluding counsel performed deficiently in failing to request a self-defense instruction where self-defense was the only proffered defense to the charge); State v. Jackson, 204 So. 3d 958, 964 (Fla. 5th DCA 2016) (concluding that counsel rendered deficient performance where she misunderstood the law …

discussed Cited "see, e.g." WILL TWIGG v. STATE OF FLORIDA Compare Cole v. State, 221 So. 3d 534 , 543−44 (Fla. 2017) (counsel’s decision to abandon duress defense and instead argue that the defendant did not knowingly participate in the crime was strategic and reasonable), with Kruse v. State, 222 So. 3d 13, 17 (Fla. 4th DCA 2017) (counsel was ineffective on the face of the record for failing to request a self-defense instruction when the evidence supported the instruction and there could be no strategic basis for not asking for the instruction as self-defense was the defendant’s only proffered defense).

discussed Cited "see, e.g." WILL TWIGG v. STATE OF FLORIDA Compare Cole v. State, 221 So. 3d 534 , 543−44 (Fla. 2017) (counsel’s decision to abandon duress defense and instead argue that the defendant did not knowingly participate in the crime was strategic and reasonable), with Kruse v. State, 222 So. 3d 13, 17 (Fla. 4th DCA 2017) (counsel was ineffective on the face of the record for failing to request a self-defense instruction when the evidence supported the instruction and there could be no strategic basis for not asking for the instruction as self-defense was the defendant’s only proffered defense).