Clair v. State of Florida — Affirmed in postconviction relief appeal

Case
Patricia Ann Clair v. State of Florida
Court
Florida Fifth District Court of Appeal
Judge
JAY (Ron DeSantis, 2023); MAKAR (Ron DeSantis, 2023)
Date Decided
July 2, 2026
Docket No.
5D2025-3491
Topics
Postconviction Relief, Criminal Appeal, Florida Procedure
Source
Read the full opinion

Background

Patricia Ann Clair appealed a Circuit Court for Citrus County order in a postconviction relief matter (Case No. 2021-CF-001301-A). Clair, proceeding pro se without counsel, sought appellate review of the Circuit Court’s decision. The State of Florida, through the Office of the Attorney General, defended the trial court’s order.

The Court’s Holding

The Fifth District Court of Appeal affirmed the Circuit Court’s order. In a brief per curiam judgment, the three-judge panel—Chief Judge Jay and Judges Makar and Soud—provided no written explanation or reasoning for the affirmance. The decision is not final pending disposition of any timely Rule 9.330 or 9.331 motion.

Key Takeaways

  • The Circuit Court’s postconviction relief determination was upheld unanimously without dissent
  • No written opinion was issued elaborating the grounds for affirmance
  • Clair’s pro se appeal was unsuccessful

Why It Matters

Bare affirmances without written opinion are routine in appellate practice when courts agree with the trial court’s judgment. However, the absence of written reasoning limits precedential value and provides no guidance on the postconviction claims or legal standards applied in this matter.

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