HENRY FERGUSON
v.
STATE OF FLORIDA

Fla. 3d DCA | 2026-03-04
No. 2025-1693
2026 FL 2361 Florida District Court of Appeal, Third District (2026)

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Holding

A defendant who fails to object at trial and on direct appeal to sentencing issues forfeits the right to challenge those issues on a motion for postconviction relief when the controlling precedent does not apply retroactively.


Key Quotes

“Rule 3.800(a) is intended to correct errors that are apparent on the face of the record.”

Saintelien v. State, 990 So. 2d 494, 497 (Fla. 2008), cited by the court to explain the limited scope of postconviction sentencing relief

Facts & Procedural History

Ferguson was sentenced and did not object to victim injury points at trial or raise the issue on direct appeal. He apparently sought postconviction re…

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Opinion of the Court

PER CURIAM. Affirmed. See Wainwright v. State, 411 So. 3d 392, 399–401 (Fla. 2025) (holding that Erlinger¹ does not apply retroactively); see also McCalister v. State, 664 So. 2d 1149, 1150 (Fla. 3d DCA 1995) (affirming sentence because defendant “failed to object to the assessing of victim injury points at trial [and] failed to raise the issue on direct appeal . . . .”), aff'd, 682 So. 2d 556 (Fla. 1996); Saintelien v. State, 990 So. 2d 494, 497 (Fla. 2008) (“[R]ule 3.800(a) is intended to correct errors that are apparent on the face of the record.”).

Footnotes
1 Erlinger v. United States, 602 U.S. 821 (2024).

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