MANASSAH JUNIOR PAUL, APPELLANT,
v.
THE STATE OF FLORIDA, APPELLEE

Fla. 3d DCA | 2016-04-20
No. 3D16-455
Before EMAS, LOGUE and SCALES, JJ.
188 So. 3d 985 Florida District Court of Appeal, Third District (2016) Positive Treatment
Cited by 1 case

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Synopsis

Paul sought clarification of a trial court order denying his motion to correct an illegal sentence. The Third District Court of Appeal treated his petition for writ of certiorari as a direct appeal and affirmed the trial court's orders denying relief under Florida Rule of Criminal Procedure 3.800(a).


Holding

The court affirmed the trial court's orders denying Paul's motion to correct illegal sentence. The court held that under the 2014 amendments to the Florida Rules of Appellate Procedure, a motion for rehearing is not abandoned upon filing a notice of appeal; instead, the final order is not deemed rendered until the trial court rules on the rehearing motion.


Headnotes

[1] A motion for rehearing is not abandoned when a notice of appeal is filed while the motion is pending.

[2] When a motion for rehearing is pending, the final order denying a motion to correct an illegal sentence is not deemed rendered until a signed order disposing of the motio…

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Key Quotes

“a double jeopardy analysis must — in accordance with section 775.021(4) — be conducted without regard to the accusatory pleading or the proof adduced at trial, even where an alternative conduct statute is implicated.”

Establishes the standard for reviewing whether a sentence is illegal under double jeopardy principles, as set forth in Roughton v. State.

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Facts & Procedural History

Paul filed a motion to correct his sentence pursuant to Rule 3.800(a). On September 16, 2015, the trial court denied the motion. Paul filed a notice o…

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Opinion of the Court
PER CURIAM.

ON MOTION FOR CLARIFICATION

PER CURIAM.

We grant Paul’s motion for clarification, withdraw our previously-issued opinion, and substitute the following opinion in its stead.

We treat Paul’s petition for writ of cer-tiorari as an appeal from the trial court’s order denying motion to correct illegal sentence and the trial court’s ameiided order denying motion to correct illegal sentence1 and affirm. See Irizarry v. State, 905 So.2d 160 (Fla. 3d DCA 2005); State v. Reardon, 763 So.2d 418 (Fla. 5th DCA 2000); Washington v. State, 752 So.2d 16 (Fla. 2d DCA 2000). See also § 775.021(4)(a)-(b), Fla. Stat. (1995); Roughton v. State, 185 So.3d 1207 (Fla. 2016) (receding: from Gibbs v. State, 698 So.2d 1206 (Fla.1997) and holding that “a double jeopardy analysis must — in accordance with section 775.021(4) — be conducted without regard to the accusatory pleading or the proof adduced at trial, even where an alternative conduct statute is implicated.”)


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