Sampson v. State — Florida appellate court dismissed mandamus petition after postconviction hearing was scheduled

Case
Johnathan Sampson v. State of Florida
Court
Florida First District Court of Appeal
Judge
Roberts; Ray; Treadwell
Date Decided
September 16, 2026
Docket No.
1D2025-3285
Topics
Mandamus, Postconviction Proceedings, Appellate Procedure
Source
Read the full opinion

Background

Johnathan Sampson filed an original petition for a writ of mandamus in the Florida First District Court of Appeal. The petition concerned a postconviction motion pending in the circuit court.

While the mandamus proceeding was pending, the circuit court scheduled an evidentiary hearing on Sampson’s postconviction motion. The appellate court did not describe the claims in that motion, the relief sought in the mandamus petition, or the timing of the scheduled hearing.

The Court’s Holding

The First District dismissed Sampson’s petition for a writ of mandamus. Its per curiam opinion relied on the circuit court’s recent scheduling of an evidentiary hearing on the pending postconviction motion.

The court cited Munn v. Florida Parole Commission, 807 So. 2d 733 (Fla. 1st DCA 2002). It offered no further analysis and did not rule on the merits of Sampson’s postconviction motion.

Key Takeaways

  • The First District dismissed the original mandamus proceeding.
  • The dismissal followed the circuit court’s scheduling of an evidentiary hearing on the pending postconviction motion.
  • The brief opinion did not identify the specific relief Sampson requested through mandamus or decide his underlying postconviction claims.

Why It Matters

The decision illustrates that developments in an underlying postconviction proceeding can affect a related mandamus case. Here, the First District treated the recently scheduled evidentiary hearing as sufficient grounds to dismiss the petition.

Because the opinion is limited to dismissal and contains little factual or legal analysis, it should not be read as resolving the merits of Sampson’s postconviction motion.

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