Henry Martin Steiger v. State of Florida

Summary

The court held that section 924.051(3) bars appellate review and reversal on direct appeal of unpreserved ineffective-assistance claims unless the defendant alleges and establishes fundamental error. Claims relying on the less-demanding ineffective-assistance standard must instead be raised in a legally sufficient postconviction motion. The court approved the First District's decision to the extent consistent with that rule, limited its prior conflicting precedent, and disapproved conflicting district-court decisions.