ARTHUR FLORIDA
v.
STATE OF FLORIDA

Fla. 4th DCA | 2026-04-22
No. 2025-3601
Holden, J., Kuntz, C.J., Klingensmith, J., Shepherd, J.
2026 FL 4682 Florida District Court of Appeal, Fourth District (2026)

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Holding

A change in law established by Erlinger v. United States does not apply retroactively to cases on collateral review.


Headnotes

[1] A change in law established by a United States Supreme Court decision does not apply retroactively to cases on collateral review absent a determination that retroactive a…

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Facts & Procedural History

Arthur Florida filed a Rule 3.800 motion in the Circuit Court for Broward County challenging his conviction. The trial court denied the motion.…

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Opinion of the Court

DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA

FOURTH DISTRICT

ARTHUR FLORIDA, Appellant,

V.

STATE OF FLORIDA, Appellee.

No. 4D2025-3601

[April 22, 2026]

Appeal of order denying rule 3.800 motion from the Circuit Court for the Seventeenth Judicial Circuit, Broward County; Peter Holden, Judge; L.T. Case No. 061995CF007349A88810.

Arthur Florida, Miami, pro se.

No appearance required for appellee.

PER CURIAM.

Affirmed. See Maye v. State, 368 So. 3d 531 (Fla. 6th DCA 2023), review granted, No. SC2023-1184, 2024 WL 1796831 (Fla. Apr. 25, 2024); Wainwright v. State, 411 So. 3d 392 (Fla. 2025) (holding that even if Erlinger v. United States, 602 U.S. 821 (2024) constitutes a change of law, it does not apply retroactively).

KUNTZ, C.J., KLINGENSMITH and SHEPHERD, JJ., concur.

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