In the early 1930s, Alfred Sawyer was charged with using an illegal net to catch fish in Florida waters and was arrested and thrown in jail. Mr. Sawyer did not deny that he was using the net described in the charging document. However, Mr. Sawyer believed that his use of the net occurred outside of Florida waters in the Gulf Stream. If true, then he could not have been guilty of the crime charged. Mr. Sawyer sought relief by filing a petition for a writ of habeas corpus. At the hearing, Mr. Sawyer testified that he was not in Florida waters when he used the net and, in support of his contention, introduced as evidence a marine chartused by the United States Navy. The State did not introduce any
evidence to contradict Mr. Sawyer’s contention, and the trial judge granted Mr. Sawyer’s petition.
On appeal, the Florida Supreme Court reversed. The Court held that defendants may not use a petition for a writ of habeas corpus to test the sufficiency of the evidence against them. So long as the State filed a charging document that was facially valid, which it did, the sheriff was empowered to detain Mr. Sawyer until his trial. It did not matter that, based on the undisputed facts, Mr. Sawyer could not be found guilty of the crime charged. Mr. Sawyer’s only recourse was to wait until trial and then, upon the State’s failure to prove that Mr. Sawyer used the net in Florida waters, to motion for a directed verdict. Until then, Mr. Sawyer was stuck in jail.