WILLIAM BULLOCK
v.
STATE OF FLORIDA

Fla. 6th DCA | 2026-03-27
No. 2024-1085
2026 FL 3419 Florida District Court of Appeal, Sixth District (2026)

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Holding

The court affirmed the sentence, finding any error to be harmless even if the defendant's argument regarding a recent Supreme Court decision applied.


Key Quotes

“We affirm without deciding Erlinger's impact . . . because, even assuming Erlinger applies, any error in this case is harmless.”

The court's explicit basis for affirming the judgment while avoiding the constitutional question.

Facts & Procedural History

Appellant argued his sentence was unconstitutional under a recent Supreme Court decision. The appellate court reviewed the case.…

The full statement of facts, procedural history, and disposition for this case are member content.

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Opinion of the Court

PER CURIAM.

SIXTH DISTRICT COURT OF APPEAL STATE OF FLORIDA

Case No. 6D2024-1085 Lower Tribunal No. 21CF006460AOR

WILLIAM BULLOCK, Appellant,

V.

STATE OF FLORIDA, Appellee.

Appeal from the Circuit Court for Orange County. Wayne C. Wooten, Judge.

March 27, 2026

AFFIRMED. See Avalos v. State, 419 So. 3d 299, 300 (Fla. 6th DCA 2025) ("[Avalos] argues his sentence . . . is unconstitutional under the United States Supreme Court's recent decision in Erlinger v. United States, 602 U.S. 821, 144 S. Ct. 1840, 219 L. Ed. 2d 451 (2024). We affirm without deciding Erlinger's impact . . . because, even assuming Erlinger applies, any error in this case is harmless.”). STARGEL, MIZE and KAMOUTSAS, JJ., concur. Blair Allen, Public Defender, and A. Victoria Wiggins, Assistant Public Defender, Bartow, for Appellant.

James Uthmeier, Attorney General, Tallahassee, and Richard A. Pallas, Jr., Assistant Attorney General, Daytona Beach, for Appellee.

NOT FINAL UNTIL TIME EXPIRES TO FILE MOTION FOR REHEARING AND DISPOSITION THEREOF IF FILED

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