Paul Anthony Brown, Appellant(s) v. State of Florida, Appellee(s)

Summary

The Florida Supreme Court affirmed the circuit court’s summary denial of Paul Anthony Brown’s successive post‑conviction motion, holding that the alleged newly discovered evidence was known or could have been discovered with due diligence and therefore the claims are procedurally barred. The Court applied a de novo standard to the rule‑3.851 evidentiary‑hearing question. Justice Quince dissented, arguing that the Brady and Giglio claims should be heard.