Public Defender, Eleventh Judicial Circuit of Florida v. State of Florida, Respondent Public Defender, Eleventh…

Summary

The court held that a public defender's request to decline future appointments is treated as a prospective withdrawal governed by the withdrawal statute, but the statute does not bar relief when excessive caseload or underfunding creates a substantial risk that representation will be materially limited. It approved aggregate or systemic withdrawal relief, held the statute facially constitutional as construed, and upheld the State Attorney's standing to oppose the motions. The court quashed the relevant appellate decisions and remanded for a determination whether the conditions justifying prospective withdrawal still existed. The separate opinion by Polston, C.J., joined by Canady, J., agreed on applicability, constitutionality, and standing but would have required individualized proof of actual or imminent constitutional harm and rejected aggregate withdrawal.