RELFORD
v.
STATE OF FLORIDA
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This case affirms a prison releasee reoffender sentence without addressing the impact of Erlinger v. United States, finding any potential error harmless. The decision follows a line of other recent appellate decisions reaching the same conclusion across multiple Florida district courts.
The court affirmed the appellant's prison releasee reoffender sentence without deciding the impact, if any, of Erlinger v. United States, determining that any potential error was harmless.
“affirming the appellant's prison releasee reoffender sentence without deciding the impact, if any, of Erlinger v. United States, 602 U.S. 821 (2024), because any error was harmless”
Establishes the court's holding that despite potential constitutional issues from Erlinger, the sentence stands as harmless error
The opinion does not provide detailed facts, relying instead on incorporation by reference to prior cases addressing the same sentencing issue.…
The full statement of facts, procedural history, and disposition for this case are member content.
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FIRST DISTRICT COURT OF APPEAL STATE OF FLORIDA
No. 1D2024-1713
COLIN TRAYELE RELFORD,
Appellant,
v. STATE OF FLORIDA,
Appellee.
On appeal from the Circuit Court for Gadsden County. Ronald W. Flury, Judge.
November 12, 2025
PER CURIAM.
AFFIRMED. See Hicks v. State, 50 Fla. L. Weekly D2238a (Fla. 1st DCA Oct. 15, 2025) (affirming the appellant's prison releasee reoffender sentence without deciding the impact, if any, of Erlinger v. United States, 602 U.S. 821 (2024), because any error was harmless); Alonso v. State, 415 So. 3d 826, 827 (Fla. 2d DCA 2025) (same); Ashford v. State, 407 So. 3d 537, 537 (Fla. 5th DCA 2025) (same).
LEWIS, ROBERTS, and TREADWELL, JJ., concur. Not final until disposition of any timely and authorized motion under Fla. R. App. P. 9.330 or 9.331.
Jessica J. Yeary, Public Defender, and Pamela D. Presnell, Assistant Public Defender, Tallahassee, for Appellant.
James Uthmeier, Attorney General, and Robert Charlie Lee, Assistant Attorney General, Tallahassee, for Appellee.
2
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Erlinger v. United States, 602 U.S. 821 (U.S. 2024)
- Erester Markque Ashford v. State, 407 So. 3d 537 (Fla. 5th DCA 2025)
- Alonso v. State, 415 So. 3d 826 (Fla. 2d DCA 2025)