Graham v. State — Florida appeals court affirmed a Rule 3.850 ruling

Case
Donald Edward Graham, Jr. v. State of Florida
Court
Florida Fifth District Court of Appeal
Judge
Edwards; Eisnaugle; Harris
Date Decided
August 25, 2026
Docket No.
5D2025-3103
Topics
Criminal Appeals; Postconviction Proceedings; Rule 3.850
Source
Read the full opinion

Background

Donald Edward Graham, Jr., proceeding without counsel, appealed a ruling from the Circuit Court for Duval County in a proceeding under Florida Rule of Criminal Procedure 3.850. Circuit Judge Jonathan D. Sacks entered the ruling under review.

The State was represented on appeal by the Florida Attorney General’s Office. The Fifth District’s opinion does not describe Graham’s claims, the circuit court’s reasoning, or the precise nature of the Rule 3.850 ruling.

The Court’s Holding

The Florida Fifth District Court of Appeal affirmed the circuit court’s Rule 3.850 ruling.

The per curiam opinion consists solely of the disposition “AFFIRMED” and provides no analysis or explanation. Judges Edwards, Eisnaugle, and Harris concurred.

Key Takeaways

  • The Fifth District affirmed the ruling in Graham’s Rule 3.850 proceeding.
  • The opinion does not identify the specific claims or the precise nature of the ruling under review.
  • The court issued a summary affirmance without a written rationale.

Why It Matters

The decision leaves the circuit court’s Rule 3.850 ruling in place. Because the appellate court supplied no reasoning, the opinion offers no substantive guidance on postconviction standards or the merits of Graham’s claims.

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