KYLE DYLAN MORAN, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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Kyle Dylan Moran appeals the summary denial of his motion challenging his mandatory life sentence without parole for first-degree murder committed at age sixteen. The court reverses and remands, holding that Miller v. Alabama applies retroactively to juvenile offenders under Florida law, requiring resentencing under the state's new juvenile sentencing legislation.
Miller v. Alabama applies retroactively to all juvenile offenders whose convictions and sentences were final when Miller was decided. The proper remedy is to apply Florida's chapter 2014-220 (codified in sections 775.082, 921.1401, and 921.1402), which provides new juvenile sentencing procedures, and resentencing must occur consistent with this legislation.
[1] A mandatory life sentence without the possibility of parole for a juvenile who commits a homicide is unconstitutional under Miller v. …
[2] Miller v. …
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Join FLexlaw to unlock all legal intelligence“Miller v. Alabama, - U.S. - , 132 S.Ct. 2455, 183 L.Ed.2d 407 (2012), did not apply retroactively”
Describes the prior holdings that the postconviction court relied upon in denying Moran's motion
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Join FLexlaw to unlock all legal intelligenceKyle Dylan Moran was convicted of first-degree murder committed when he was sixteen years old and received a mandatory sentence of life imprisonment w…
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Kyle Dylan Moran appeals the summary denial of his motion filed pursuant to Florida Rule of Criminal Procedure 3.800(a). Mr. Moran’s motion alleged that he received a mandatory sentence of life in prison without the possibility of parole for a .first-degree murder that he committed when he was sixteen years old. The motion was denied based on Geter v. State, 115 So.3d 375 (Fla. 3d DCA 2012), and Gonzalez v. State, 101 So.3d 886 (Fla. 1st DCA 2012), which held that Miller v. Alabama, - U.S. - , 132 S.Ct. 2455, 183 L.Ed.2d 407 (2012), did not apply retroactively. The Florida Supreme Court has recently held that the Miller decision applies retroactively to all juvenile offenders whose convictions and sentences were final *69when Miller was decided. Falcon v. State, 162 So.3d 954, (Fla. Mar. 19, 2015). Accordingly, we reverse the postconviction court’s order summarily denying the claim.
We note that the Florida Supreme Court has further held in Horsley v. State, 160 So.3d 393 (Fla.2015), that the proper remedy in cases involving juvenile offenders whose sentences are unconstitutional under Miller is to apply chapter 2014-220, Laws of Florida. The court concluded that “applying chapter 2014-220, Laws of Florida, to all juvenile offenders whose sentences are unconstitutional under Miller is the remedy most faithful to the Eighth Amendment principles established by the United States Supreme Court, to the intent of the Florida Legislature, and to the doctrine of separation of powers.” Id. at 406. The relevant provisions of chapter 2014-220 have been codified in sections 775.082, 921.Í401, and 921.1402, Florida Statutes (2014). Accordingly, we reverse the order denying Mr. Moran’s motion and remand for a resentencing proceeding consistent with this new juvenile sentencing legislation. See Horsley, 160 So.3d 393; Falcon, 162 So.3d 954,.
Reversed and remanded with directions.
WALLACE and KHOUZAM, JJ., Concur.
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Citator
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State v. Moran, 310 So. 3d 972 (Fla. 2d DCA 2020)…uant to Florida Rule of Criminal Procedure 3.800(a). The trial court denied the motion, finding that Miller did not apply retroactively. We reversed and "remand[ed] for a resentencing proceeding consistent with [section 775.082]." Moran v. State, 164 So. 3d 68, 68 (Fla. 2d DCA 2015). On remand, Mr. Moran moved to declare section 775.082(1)(b)(1) unconstitutional. He argued that the mandatory minimum forty-year sentence ran afoul of Miller because it "divests the trial court of any meaningful sentencing d…
Authorities Cited
- Miller v. Alabama, 567 U.S. 460 (U.S. 2012)
- Horsley v. State, 160 So. 3d 393 (Fla. 2015)
- Falcon v. State, 162 So. 3d 954 (Fla. 2015)
- Drewery Geter v. State, 115 So. 3d 375 (Fla. 3d DCA 2012)
- Gonzalez v. State, 101 So. 3d 886 (Fla. 1st DCA 2012)