Michael Bernard Bell v. State of Florida

Summary

The court affirmed the summary denial of Bell’s second successive postconviction motion as untimely and procedurally barred. It held that the federal decision invoked by Bell did not establish a new constitutional right or per se ineffective-assistance rule, but instead applied the established ineffective-assistance standard to particular facts. The court also held that Bell’s underlying arguments had already been rejected in his initial postconviction proceeding.