LAWSON
v.
STATE OF FLORIDA

Fla. 1st DCA | 2025-11-05
No. 2023-3115
2025 FL 9978 Florida District Court of Appeal, First District (2025)

AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.

Synopsis

Dexter Lawson appeals his convictions for attempted murder, theft, and tampering with evidence, challenging both trial procedure and his sentence enhancement as a prison releasee reoffender. The court affirms, rejecting his claims about reopening his case, prosecutorial error in closing argument, and sentencing unconstitutionality, finding any sentencing error harmless beyond a reasonable doubt.


Holding

The court rejected all three claims. The court held that even assuming the court erred in failing to require a jury determination for the prison releasee reoffender status, any such error was harmless beyond a reasonable doubt.


Headnotes

[1] A trial court does not abuse its discretion by denying a defendant's request to reopen their case after the close of evidence, absent a showing of fundamental error.

[2] Alleged errors in a prosecutor's closing argument do not constitute fundamental error unless they are so egregious as to deprive the defendant of a fair trial.

Previewing 2 of 4 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.

Join FLexlaw to unlock all legal intelligence

Key Quotes

“Even if we presume that the court erred by failing to require a jury determination, we find that such error was harmless beyond a reasonable doubt.”

Establishes the court's harmless error analysis for the sentencing enhancement claim

Previewing 1 of 2 key quotes on this case — the court’s exact language, pinpointed for members.

Join FLexlaw to unlock all legal intelligence

Facts & Procedural History

Lawson was convicted of attempted murder, theft, and tampering with evidence. At sentencing, he was enhanced as a prison releasee reoffender based on …

The full statement of facts, procedural history, and disposition for this case are member content.

Join FLexlaw to unlock all legal intelligence

© FLexlaw, Inc. — AI-generated enrichments are proprietary. All rights reserved.


Per_curiam
Per Curiam

FIRST DISTRICT COURT OF APPEAL STATE OF FLORIDA

No. 1D2023-3115

DEXTER LAWSON,

Appellant,

V.

STATE OF FLORIDA,

Appellee.

On appeal from the Circuit Court for Gadsden County. James Lee Marsh, Judge.

November 5, 2025

PER CURIAM.

Dexter Lawson appeals his convictions of attempted murder, theft, and tampering with evidence. We reject his claims that the trial court erred in failing to permit him to reopen his case and that fundamental error occurred in the State's closing argument. Lawson also claims that his sentence as a prison releasee reoffender was unconstitutional because the determination of whether he was released from prison within three years of committing his current offense was not made by the jury. Even if we presume that the court erred by failing to require a jury determination, we find that such error was harmless beyond a reasonable doubt. *Hicks v. State*, 50 Fla. L. Weekly D2238a (Fla. 1st DCA Oct. 15, 2025); *Dowdell v. State*, 50 Fla. L. Weekly D2236c

(Fla. 1st DCA Oct. 15, 2025); *McGlaun v. State*, 50 Fla. L. Weekly D2178a (Fla. 1st DCA Oct. 1, 2025).

AFFIRMED.

RAY and KELSEY, JJ., concur. WINOKUR, J., concurs with opinion.


Cases With Similar Vibessemantic neighbors from the corpus

Full citator, related cases, and AI research tools

Open in FLexlaw