JUNIOR BEAUBRUM
v.
STATE OF FLORIDA

Fla. 3d DCA | 2025-07-02
No. 2025-0882
2025 FL 5524 Florida District Court of Appeal, Third District (2025)

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Synopsis

Beaubrum appeals the denial of his motion to correct an illegal sentence, arguing that his life sentence constitutes an impermissibly indefinite term of imprisonment. The court affirms, holding that a life sentence is sufficiently definite under Florida law and does not violate constitutional protections against indefinite imprisonment.


Holding

A life sentence is sufficiently definite and does not create an illegal indefinite term of imprisonment. The court rejected the argument that the judicial system's inability to predict exactly how long the defendant will live renders the sentence unconstitutionally indefinite.


Headnotes

[1] A sentence of life imprisonment is not an illegal indefinite term of imprisonment.

[2] The term "life" in a sentence is sufficiently definite and understandable.

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Key Quotes

“The fact that the judicial system has no way of knowing how long the defendant will live and therefore cannot know how long the defendant will be incarcerated does not render a life sentence unconstitutionally indefinite. It is abundantly clear that the Legislature, by prescribing a sentence of life imprisonment, intends that the defendant remain in prison for the rest of his life. The term 'life' is sufficiently definite so that it can be understood and applied. There is nothing indefinite about such a sentence.”

Establishes the core holding that life sentences are constitutionally definite and not indefinite imprisonment

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Facts & Procedural History

Beaubrum was sentenced to life in prison. He filed a rule 3.800(a) motion challenging his sentence as illegal because it allegedly created an indefini…

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Opinion of the Court

Third District Court of Appeal

State of Florida

Opinion filed July 2, 2025.

Not final until disposition of timely filed motion for rehearing.

No. 3D25-0882 Lower Tribunal No. F88-31912D

Junior Beaubrum, Appellant,

vs.

State of Florida, Appellee.

An Appeal under Florida Rule of Appellate Procedure 9.141(b)(2) from the Circuit Court for Miami-Dade County, Jason Bloch, Judge.

Junior Beaubrum, in proper person.

James Uthmeier, Attorney General, and Ivy R. Ginsberg, Assistant Attorney General, for appellee.

Before MILLER, GORDO and BOKOR, JJ.

GORDO, J.

Junior Beaubrum (“Beaubrum") appeals the denial of his rule 3.800(a) motion to correct illegal sentence. We have jurisdiction. Fla. R. App. P. 9.140(b)(1)(D). Beaubrum argues he was sentenced to life in prison and his sentence has created an illegal indefinite term of imprisonment. Because the term "life" is sufficiently definite and there is nothing indefinite about such a sentence, we affirm. See Ratliff v. State, 914 So. 2d 938, 940 (Fla. 2005) ("The fact that the judicial system has no way of knowing how long the defendant will live and therefore cannot know how long the defendant will be incarcerated does not render a life sentence unconstitutionally indefinite. It is abundantly clear that the Legislature, by prescribing a sentence of life imprisonment, intends that the defendant remain in prison for the rest of his life. The term 'life' is sufficiently definite so that it can be understood and applied. There is nothing indefinite about such a sentence.”); Johnson v. Crosby, 897 So. 2d 546, 547 (Fla. 3d DCA 2005) (“A life sentence is not impermissible 'indefinite imprisonment' for purposes of Article I, Section 17 of the Florida Constitution.").

Affirmed.


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