RACHAUN BLOUNT
v.
STATE OF FLORIDA
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Trial courts lack authority to disregard appellate court mandates even when an intervening Florida Supreme Court decision contradicts the appellate court's prior ruling.
[1] Trial courts are bound by appellate court mandates and lack authority to disregard them based on intervening contrary decisions from higher courts, as the finality of jud…
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The court explained the finality of judgment principle in Howard v. State, rejecting the exception to the law of the case doctrine previously recognized in Marshall.
Blount appealed a sentencing order and obtained a reversal and remand for resentencing under new juvenile sentencing guidelines in 2018. The postconvi…
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PER CURIAM. Rachaun Blount appeals the order dismissing his motion to correct sentencing error filed in 2017 under Florida Rule of Criminal Procedure 3.800(a). The State has correctly conceded error.
We reverse the postconviction court's order and remand for resentencing. In Blount v. State, 238 So. 3d 913, 913–14 (Fla. 2d DCA 2018), we reversed the postconviction court's order denying Blount's rule 3.800(a) motion and remanded for resentencing under the then new juvenile sentencing guidelines. After our mandate issued, the postconviction court granted the State's request for a stay pending the Florida Supreme Court's decision in Pedroza v. State, 291 So. 3d 541 (Fla. 2020).
Pedroza expressly disapproved Blount. Id. at 549.
The postconviction court then dismissed Blount's motion in reliance on Marshall v. State, 313 So. 3d 671, 672 (Fla. 2d DCA 2019), in which this court denied a motion to enforce mandate based on the exception to the law of the case doctrine for a contrary intervening supreme court decision. But we have receded from Marshall and reiterated the finality of judgment principle that trial courts do not have authority to disregard this court's mandates. See Howard v. State, 322 So. 3d 134, 135, 137–38 (Fla. 2d DCA 2021) (en banc).
Accordingly, we reverse the postconviction court's order and remand for resentencing in accordance with the mandate in Blount, 238 So. 3d at 913–14. Reversed and remanded. MORRIS, C.J., and BLACK and LABRIT, JJ., Concur. Opinion subject to revision prior to official publication.
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Citator
Authorities Cited
- Rachaun Blount v. State, 42 Fla. L. Weekly D2181 (Fla. 2d DCA 2018)
- Dante R. Morris v. State (Fla. 2d DCA 2021)