NATHAN COLSON
v.
STATE OF FLORIDA

Fla. 4th DCA | 2026-02-25
No. 2025-3736
Bober, J., Gerber, J., Conner, J., Shaw, J.
2026 FL 2135 Florida District Court of Appeal, Fourth District (2026)

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Holding

A change in law established by Erlinger v. United States does not apply retroactively to cases on collateral review.

Headnotes

[1] A change in law does not apply retroactively to cases on collateral review unless the change is deemed retroactive under applicable retroactivity doctrine.

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Facts & Procedural History

Nathan Colson appealed the denial of his rule 3.850 motion for post-conviction relief in a criminal case from Broward County.…

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Topics
Rule 3.850 Motion For Post-Conviction Relief Rule 3.850 Retroactive Application Of Statutes Motion For Postconviction Relief

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Opinion of the Court

DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA FOURTH DISTRICT NATHAN COLSON, Appellant, v. STATE OF FLORIDA, Appellee. No. 4D2025-3736 [February 25, 2026] Appeal of order denying rule 3.850 motion from the Circuit Court for the Seventeenth Judicial Circuit, Broward County; Bernard Isaac Bober, Judge; L.T. Case No. 062018CF000204A88810. Nathan Colson, Monticello, pro se. No appearance required for appellee. PER CURIAM. Affirmed. See Wainwright v. State, 411 So. 3d 392 (Fla. 2025) (holding that, even if Erlinger v. United States, 602 U.S. 821 (2024), constitutes a change of law, it does not apply retroactively); see also Maye v. State, 368 So. 3d 531, 532 (Fla. 6th DCA 2023), rev. granted, No. SC2023-1184, 2024 WL 1796831 (Fla. Apr. 25, 2024). GERBER, CONNER and SHAW, JJ., concur. * * * Not final until disposition of timely-filed motion for rehearing.

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