Kim Jackson v. State of Florida & Kim Jackson v. Ricky D. Dixon

Summary

The court affirmed the denial of Jackson’s guilt-phase postconviction claims and denied his habeas petition. It held that Jackson failed to establish deficient performance or prejudice under the governing ineffective-assistance standard, and it rejected his appellate-counsel claim because the unraised prosecutorial comments were not fundamental error. The court also abandoned Florida’s prior balancing approach for preindictment delay and held that such a due process claim requires substantial prejudice and State bad faith.