JASON L. WILLIAMS, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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Jason L. Williams appeals the denial of his motion to correct sentence challenging his habitual felony offender (HFO) and prison releasee reoffender (PRR) designations. The appellate court holds that while the PRR designation challenge is not improperly successive and must be reconsidered on the merits, the HFO designation challenge remains affirmed.
The PRR designation challenge is not improperly successive because the first motion was dismissed on procedural grounds rather than on the merits, and the instant motion cures the facial insufficiency by including specific record attachments. The court affirms the HFO designation challenge but reverses and remands regarding the PRR designation for the trial court to address on the merits.
[1] A motion to correct sentence under Rule 3.800(a) must present an error apparent from the face of the record and cannot require an evidentiary hearing.
[2] Appellate review of a trial court's ruling on a motion to correct sentence, where no evidentiary hearing is required, is de novo.
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Join FLexlaw to unlock all legal intelligence“The error to be corrected in a rule 3.800(a) motion must be apparent from the face of the record.”
Establishes the foundational requirement that such motions address only errors visible in the record without requiring evidentiary hearings.
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Join FLexlaw to unlock all legal intelligenceWilliams was convicted of robbery while masked and two counts of grand theft, receiving a life sentence with a thirty-year minimum mandatory for robbe…
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Jason L. Williams appeals the denial of his motion to correct sentence filed pursuant to Florida Rule of Criminal Procedure 3.800(a). We affirm in part and reverse in part.
Williams was convicted of robbery while masked and two counts of grand theft. He was sentenced to life in prison with a thirty-year minimum mandatory for the robbery, and ten years in prison for the grand thefts. Additionally," he was designated as both a habitual felony offender (HFO) and a prison releasee reoffender (PRR). This Court affirmed Williams’s judgment and sentence on appeal. Williams v. State, 134 So.3d 965 (Fla. 5th DCA 2014).
Williams filed his first motion to correct sentence, challenging his HFO and PRR designations. The trial court dismissed the motion not on the merits, but as facially insufficient. Williams appealed, and this Court affirmed. Williams v. State, No. 5D17-162, 2017 WL 1829579 (Fla. 5th DCA May 2, 2017). Williams then filed the instant motion to correct sentence, raising the same challenge to his HFO and PRR designations but now including record attachments. The trial court denied relief, rilling that the instant motion was improperly successive. This-appeal-follows;
The error to 'be corrected in a rule 3.800(a) motion must be apparent from the face of the record. Johnson v. State, 60 So.3d 1045, 1049 (Fla. 2011). Accordingly, such a motion cannot require an evidentiary hearing. Id. A.s no evidentiary hearing is required or permitted, this Court is presented with pure issues of law on appeal, and applies the de novo standard of review. Smith v. State, 143 So.3d 1023, 1024 (Fla. 4th DCA 2014).
While rule 3.800(a) permits a defendant to file successive motions, a defendant is precluded from re-litigating the same issue previously decided on the merits in a successive rule 3.800(a) motion. See State v. McBride, 848 So.2d 287, 290-91 (Fla. 2003) ‘(noting that, by “barring the filing of successive repetitive 3.800 • motions, [Florida appellate] courts essentially have applied collateral estoppel principles”); Ellis v. State, 853 So.2d 484, 485 (Fla. 5th DCA 2003) (explaining defendant’s successive rule 3.800(a) motion violated law of case doctrine).
In his successive motion, Williams alleges his PRR designation is illegal because the trial court used the wrong dates in determining whether he committed the requisite offenses within the three-year statutory time frame. Williams’s prior motion was dismissed as facially insufficient because he failed to allege which court records would show that his PRR designation was improper. The instant motion corrects that deficiency and is facially sufficient. Because the first motion was not denied on the merits, the instant motion is not improperly successive and should be considered by the trial court as to the PRR designation. However, we affirm as to the HFO designation without further discussion. Accordingly, we reverse and *964remand for the trial court to address the PRR claim on the merits.
AFFIRMED in part;- REVERSED in part; and REMANDED.
BERGER and WALLIS, JJ., concur.
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Jimenez v. State, 265 So. 3d 462 (Fla. 2018)…tching from lethal injection to nitrogen gas, his fifth successive postconviction motion states that he "has not had adequate time to research and consult with an expert about this method." The standard of review is de novo. See Williams v. State , 235 So. 3d 962, 963 (Fla. 5th DCA 2017) ("The error to be corrected in a rule 3.800(a) motion must be apparent from the face of the record. Johnson v. State , 60 So. 3d 1045, 1049 (Fla. 2011). Accordingly, such a motion cannot require an evidentiary hearing. Id. A…
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Burks v. State, 283 So. 3d 864 (Fla. 3d DCA 2019)…. STANDARD OF REVIEW As “[t]he error to be corrected in a rule 3.800(a) motion must be apparent from the face of the record,” the court “is presented with pure issues of law on appeal, and applies the de novo standard of review.” Williams v. State, 235 So. 3d 962, 963 (Fla. 5th DCA 2017). LEGAL ANALYSIS “No person shall . . . be subject for the same [offense] to be twice put in jeopardy of life or limb.” Amend. V, U.S. Const. Nonetheless, “[a]s it relates to barring multiple punishments for the same offe…
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Thomas v. State (Fla. 5th DCA 2020)…nces and running them consecutively to each other and the underlying concurrent sentences in his latter two cases in the manner previously described. Our review of the denial of a motion to correct an illegal sentence is de novo. Williams v. State, 235 So. 3d 962, 963 (Fla. 5th DCA 2017). 2 As a result, Thomas’s now-corrected five-year concurrent prison sentence on this count, together with its concomitant three-year mandatory minimum provision that was ordered to be served concurrently with the three-year m…
Previewing 3 of 5 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- State v. Antoine L. McBRIDE, 848 So. 2d 287 (Fla. 2003)
- Johnson v. State, 60 So. 3d 1045 (Fla. 2011)
- Smith v. State, 143 So. 3d 1023 (Fla. 4th DCA 2014)
- Deorick Ellis v. State, 853 So. 2d 484 (Fla. 5th DCA 2003)