TIMOTHY WADE COFFELL
v.
STATE OF FLORIDA
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The court reversed a defendant's sentence imposed under Florida's sentencing statute because the trial court made factual findings, unrelated to prior convictions, that increased the maximum sentence beyond what was authorized by statute, violating the Sixth Amendment principles established in Apprendi v. New Jersey and Blakely v. Washington. Following its prior decision in Booker v. State, the court held that such factual findings must be made by a jury or admitted by the defendant, not by judicial determination alone.
The court reversed Coffell's sentence, holding that section 775.082(10) was unconstitutional as applied because the trial court made factual findings beyond the jury's verdict that increased his maximum sentence, in violation of Apprendi and Blakely. The court remanded for resentencing under the prior version of the statute.
[1] A trial court's factual findings that increase a defendant's maximum sentence, even when based on prior convictions supplemented by other aggravating factors, must be det…
Previewing 1 of 1 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“section 775.082(10) was unconstitutional as applied to Booker because it authorized the trial court to make factual findings that increased his maximum sentence from one year in county jail to four years in prison, contrary to the holdings in Apprendi and Blakely v. Washington”
Court's explanation of controlling precedent from Booker v. State requiring reversal here
Coffell was sentenced under section 775.082(10) of Florida law, which authorizes enhanced sentencing based on a finding that a nonstate prison sanctio…
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unconstitutional under Apprendi v. New Jersey, 530 U.S. 466 (2000), because the finding of danger to the public was not made by a jury.
The outcome of this case is controlled by our recent decision in Booker v. State, 244 So. 3d 1151 (Fla. 1st DCA 2018), where we held that section 775.082(10) was unconstitutional as applied to Booker because it authorized the trial court to make factual findings that increased his maximum sentence from one year in county jail to four years in prison, contrary to the holdings in Apprendi and Blakely v. Washington, 542 U.S. 296 (2004). Id. at 1156-64. But see Brown v. State, 233 So. 3d 1262 (Fla. 5th DCA 2017), review granted, SC18-323, 2018 WL 2069393 (Fla. Apr. 9, 2018). Here, the trial court made factual findings that increased Appellant’s maximum sentence from one year in jail to three years in prison. Therefore, as required by Booker, we reverse Appellant’s sentence and remand for resentencing under the prior version of section 775.082(10). See 244 So. 3d at 1168-69.
REVERSED and REMANDED.
WOLF and LEWIS, JJ., concur; ROWE, J., concurs with opinion.
_____________________________ Not final until disposition of any timely and authorized motion under Fla. R. App. P. 9.330 or 9.331.
_____________________________ ROWE, J, concurring.
I fully concur with the majority opinion and write only to address the State’s argument that Coffell’s sentence was not unconstitutional or in conflict with the holdings in Apprendi or Blakely because the trial court made explicit findings based on Coffell’s prior convictions to support its finding that the imposition of a nonstate prison sanction would present a danger to the public. Contrary to the State’s argument, the record demonstrates that the trial court did not rely solely on Coffell’s prior convictions when it decided to impose a state prison sentence pursuant to section 775.082(10). Instead, the trial court made several findings unrelated to Coffell’s prior convictions including the following: that a number of firearms were located in Coffell’s residence, that some of the firearms were hidden in a couch, that Coffell lived in a trailer park with nearby residents, and that Coffell possessed the firearms “to protect the cannabis that he was in possession of at the time of the search warrant.” Because the court’s order reflects that the court relied on more than just Coffell’s prior convictions when it imposed his sentence, I agree we are constrained by our decision in Booker v. State, 244 So. 2d 1151 (Fla. 1st DCA 2018), to reverse and remand for resentencing.
_____________________________ Andy Thomas, Public Defender, and Megan Long, Assistant Public Defender, Tallahassee, for Appellant.
Pamela Jo Bondi, Attorney General, and Quentin Humphrey, Assistant Attorney General, Tallahassee, for Appellee.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Apprendi v. New Jersey, 530 U.S. 466 (U.S. 2000)
- Blakely v. Washington, 542 U.S. 296 (U.S. 2004)
- Booker v. State, 244 So. 3d 1151 (Fla. 1st DCA 2018)
- Brown v. State, 233 So. 3d 1262 (Fla. 5th DCA 2017)