Filed Date: 1973
Closed Date: 1974
Clearinghouse coding complete
In 1971, indigent criminal defendants who had been separately convicted of Florida crimes filed a class action lawsuit in the United States District Court for the Middle District of Florida against the state public defender offices pursuant to state law and 42 U.S.C.A. § 1983. Plaintiffs were represented by private counsel. They alleged that the public defender's office failed to meet minimum constitutional standards of effective representation due to inadequate funding and excessive caseloads. The District Court dismissed the complaint on four grounds: (1) a Public Defender is not a state actor when he carries out his central function of representing indigents; (2) the class action was not maintainable because the deprivation of the right to effective assistance of counsel can only be proven by reference to particular instances; (3) there were adequate remedies at law; and (4) there was no case or controversy. Plaintiffs appealed.
On September 16, 1974 the United States Court of Appeals for the Fifth Circuit (Godbold, C.J.) affirmed the dismissal of the class action suit because it should not have been brought in federal court since the complaint did not allege that any of the named plaintiffs themselves were injured by the conduct of the public defenders.
Summary Authors
Dayna Frenkel (2/25/2009)
Johnson, Tomothy A. Jr. (Florida)
Zewadski, William K. (Florida)
Harrison, Baya III (Florida)
Shevin, Robert L. (Florida)
Last updated April 5, 2024, 3:01 a.m.
Docket sheet not available via the Clearinghouse.State / Territory: Florida
Case Type(s):
Key Dates
Filing Date: 1973
Closing Date: 1974
Case Ongoing: No
Plaintiffs
Plaintiff Description:
Indigent criminal defendants seeking declaratory and injunctive relief against the Florida Public Defender Offices for failing to meet minimum constitutional standards in their representation.
Plaintiff Type(s):
Public Interest Lawyer: No
Filed Pro Se: No
Class Action Sought: Yes
Class Action Outcome: Unknown
Defendants
State Public Defender Office, State
Case Details
Causes of Action:
Available Documents:
Outcome
Prevailing Party: Defendant
Nature of Relief:
Source of Relief:
Issues
Reproductive rights:
General:
Jails, Prisons, Detention Centers, and Other Institutions: