Jastrome v. State — Affirmed denial of postconviction relief without explanation

Case
St. Juste Jastrome v. State of Florida
Court
Florida Fourth District Court of Appeal
Judge
CONNER; FORST; SHAW
Date Decided
September 17, 2026
Docket No.
4D2026-1568
Topics
Postconviction Relief; Rule 3.850; Summary Affirmance
Source
Read the full opinion

Background

St. Juste Jastrome appealed an order of the Circuit Court for the Fifteenth Judicial Circuit in Palm Beach County denying his motion for postconviction relief under Florida Rule of Criminal Procedure 3.850. Circuit Judge James Nutt entered the challenged order.

Jastrome represented himself on appeal. The Fourth District stated that no appearance was required for the State.

The Court’s Holding

The Fourth District Court of Appeal affirmed the order denying Jastrome’s rule 3.850 motion.

The per curiam opinion provided no reasoning, discussed no claims, and cited no authority. Judges Conner, Forst, and Shaw concurred.

Key Takeaways

  • The denial of Jastrome’s rule 3.850 motion was affirmed.
  • The appellate court did not identify or analyze the grounds raised in the motion.
  • The opinion was not final until disposition of any timely filed motion for rehearing.

Why It Matters

The decision leaves the circuit court’s denial of postconviction relief in place. Because the opinion contains no legal analysis, it offers no stated rationale or broader guidance regarding rule 3.850 claims.

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