WILLIE SANDERS, PETITIONER,
v.
STATE OF FLORIDA, RESPONDENT
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The Florida Supreme Court reviewed Sanders' challenge to his concurrent life sentences imposed under the Prison Releasee Reoffender Act. The Court approved the Fifth District's affirmance, rejecting all of Sanders' constitutional challenges to the Act as previously resolved in prior Supreme Court decisions.
The Court affirmed Sanders' sentences, holding that all of his challenges to the Act were without merit as they had been previously resolved by the Court in McKnight, Grant, Ellis, and Cotton. The Act does not violate separation of powers, is not void for vagueness, does not violate due process, and does not constitute ex post facto punishment.
[1] A defendant has the right to present evidence to prove ineligibility for sentencing under the Prison Releasee Reoffender Act and to challenge the State's evidence regardi…
[2] An ex post facto challenge to the Prison Releasee Reoffender Act will be rejected.
Previewing 2 of 5 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“a defendant has the right both to present evidence to prove that the defendant does not qualify for sentencing under the Act and to challenge the State's evidence regarding the defendant's eligibility for sentencing as a prison releasee reoffender”
Establishes defendants' procedural rights to challenge sentencing eligibility under the Act
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Join FLexlaw to unlock all legal intelligenceWillie Sanders was sentenced to concurrent life sentences under the Prison Releasee Reoffender Act. Sanders challenged these sentences on multiple con…
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LEWIS, J.
We have for review the decision in Sanders v. State, 737 So. 2d 589 (Fla. 5th DCA 1999), in which the Fifth District affirmed Sanders’ concurrent life sentences under the Prison Releasee Reoffen-der Act1 (the “Act”), citing, inter alia, Woods v. State, 740 So. 2d 20 (Fla. 1st DCA 1999), approved sub nom. State v. Cotton, 769 So. 2d 345 (Fla.2000). We have jurisdiction. See art. V, § 3(b)(3), Fla. Const. Sanders challenges his concurrent life sentences under the Act on several grounds, all of which have already been addressed by this Court in other opinions. See McKnight v. State, 769 So. 2d 1039 (Fla.2000) (holding that a defendant has the right both to present evidence to prove that the defendant does not qualify for sentencing under the Act and to challenge the State’s evidence regarding the defendant’s eligibility for sentencing as a prison releasee reoffender); Grant v. State, 770 So. 2d 655 (Fla.2000) (rejecting an ex post facto challenge to the Act); Ellis v. State, 762 So. 2d 912, 912 (Fla.2000) (recognizing that, “[a]s to notice, publication in the Laws of Florida or the Florida Statutes gives all citizens constructive notice of the consequences of their actions”) (quoting State v. Beasley, 580 So. 2d 139, 142 (Fla.1991)); State v. Cotton, 769 So. 2d 345 (Fla.2000) (holding that the Act does not violate separation of powers, is not void for vagueness, and does not violate principles of due process by allowing a “victim veto” precluding application of the Act). Accordingly, the decision in Sanders is approved to the extent it is consistent with Cotton,
Ellis, McKnight, and Grant
It is so ordered.
WELLS, C.J., and SHAW, HARDING, ANSTEAD and PARIENTE, JJ, concur. QUINCE, J., dissents with an opinion.
. See § 775.082(8), Fla. Stat. (1997).
. In its decision in Sanders, the Fifth District cited to its decision in Speed v. State, 732 So. 2d 17 (Fla. 5th DCA 1999), approved, 779 So. 2d 265 (Fla.2001). In our decision in Cotton, we disapproved the opinion in Speed to the extent that it implied, in dicta, that a subsection of the Act gives to each victim a veto over the imposition of the mandatory sentences that are prescribed in other parts of the Act.
QUINCE, J.,
dissenting.
I dissent for the reasons stated in my dissent in State v. Cotton, 769 So. 2d 345, 358-59 (Fla.2000).
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Grant v. State, 770 So. 2d 655 (Fla. 2000)
- State v. Cotton, 769 So. 2d 345 (Fla. 2000)
- State v. Beasley, 580 So. 2d 139 (Fla. 1991)
- Woods v. State, 740 So. 2d 20 (Fla. 1st DCA 1999)
- Ellis v. State, 762 So. 2d 912 (Fla. 2000)
- McKNIGHT v. State, 769 So. 2d 1039 (Fla. 2000)
- Speed v. State, 732 So. 2d 17 (Fla. 5th DCA 1999)
- Speed v. State, 779 So. 2d 265 (Fla. 2001)
- Sanders v. State, 737 So. 2d 589 (Fla. 5th DCA 1999)