RICARDO GALARRAGA
v.
STATE OF FLORIDA
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A change in law established by Erlinger v. United States does not apply retroactively to cases that were final before the decision.
[1] A change in law established by a United States Supreme Court decision does not apply retroactively to convictions that became final before the decision was issued.
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Join FLexlaw to unlock all legal intelligenceRicardo Galarraga appealed the denial of a Rule 3.800 motion in a criminal case from Broward County. The motion was filed in a case with a conviction …
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DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA FOURTH DISTRICT
RICARDO GALARRAGA, Appellant,
v.
STATE OF FLORIDA, Appellee.
No. 4D2025-3236
[March 11, 2026]
Appeal of order denying rule 3.800 motion from the Circuit Court for the Seventeenth Judicial Circuit, Broward County; Michael A. Usan, Judge; L.T. Case No. 99003598CF10A.
Mark H. Klein, MHK Legal, PLLC, Boca Raton, for appellant.
James Uthmeier, Attorney General, Tallahassee, and Rachael Kaiman, Senior Assistant Attorney General, West Palm Beach, for appellee.
PER CURIAM.
Affirmed. See Maye v. State, 368 So. 3d 531 (Fla. 6th DCA 2023), review granted, No. SC2023-1184, 2024 WL 1796831 (Fla. Apr. 25, 2024); 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).
CIKLIN, CONNER and KLINGENSMITH, JJ., concur.
* * *
Not final until disposition of timely-filed motion for rehearing.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Erlinger v. United States, 602 U.S. 821 (U.S. 2024)
- Wainwright v. State, 411 So. 3d 392 (Fla. 2025)
- Magneson v. State, 368 So. 3d 531 (Fla. 4th DCA 2024)