The case involved a defendant charged with resisting arrest with violence who filed a motion for speedy trial the day after his arrest but before an information was filed, followed by a motion to discharge that the trial court granted. The district court of appeal reversed the speedy trial ruling, finding the pre-information motion a nullity, but treated the discharge motion as a habeas corpus petition and upheld the defendant's discharge from prosecution. The Florida Supreme Court agreed that the early speedy trial motion was invalid under prior precedent but held that the district court erred in granting habeas relief, as such issues are more appropriately addressed at trial per Sangaree v. Hamlin. Accordingly, the court quashed the portion of the district court's order granting habeas corpus relief and discharging the defendant.

criminal lawprocedure

The case involved a surety company that issued a performance bond for a general contractor after the contractor obtained signed indemnity agreements and financial statements from two subcontractors; the contractor had told the subcontractors the documents were needed for them to be bonded on the project. After the contractor defaulted and the surety incurred costs to complete the work, it sought reimbursement from the subcontractors under the indemnity agreements, but the subcontractors sued in equity to rescind those agreements on grounds of misrepresentation and failure to read the documents. The trial court granted rescission, but the Florida Supreme Court reversed, holding the agreements enforceable. The court reasoned there was no evidence the contractor acted as the surety's agent when procuring the signatures, the subcontractors knew the contractor's independent status, and a party who signs a contract without reading it is bound absent fraud by the other contracting party or special excusing circumstances.

business & regulatory