RELFORD
v.
STATE OF FLORIDA

Fla. 1st DCA | 2025-11-12
No. 2024-1713
2025 FL 10513 Florida District Court of Appeal, First District (2025)

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Synopsis

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.


Holding

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.


Key Quotes

“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

Facts & Procedural History

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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Per_curiam
Per Curiam

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


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