David Kelsey Sparre v. State of Florida

Summary

The court affirmed the summary denial of Sparre’s successive postconviction motion challenging alleged inaccuracies in his presentence investigation report. It held that no evidentiary hearing was required because the claim was untimely, procedurally barred, and legally insufficient. The alleged deficiencies could have been discovered through due diligence, and related PSI claims had already been raised and rejected.