The Third DCA dismissed a petition for belated appeal from a pro se litigant who had been barred from filing in the trial court under Spencer, explaining that without a lower court order to review, the appellate court lacks jurisdiction — making a trial court filing bar effectively the ‘end of the road.’
The First DCA affirmed the admission of crime scene photographs showing a Confederate flag tag on the defendant’s vehicle, finding no abuse of discretion where the photos were relevant to damage and paint transfer, the tag could not be redacted without losing evidence, and the State did not dwell on the images.
The Fourth DCA reversed three of the defendant’s drug convictions on double jeopardy grounds, holding that simple possession is subsumed by possession with intent to sell, and that identically-charged trafficking counts for the same date violate the prohibition against multiple punishments for the same offense.