CURTIS EDWARD NOWLING
v.
STATE OF FLORIDA

Fla. 6th DCA | 2026-05-15
No. 2025-0879
Thompson, J., Stargel, J., Wozniak, J., Pratt, J.
2026 FL 5835 Florida District Court of Appeal, Sixth District (2026)

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Holding

A sentence of life imprisonment is sufficiently definite and constitutes a valid sentence under Florida law.


Headnotes

[1] A sentence of life imprisonment is sufficiently definite under Florida law to constitute a valid sentence, as the Legislature intends such a sentence to mean the defendan…

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Key Quotes

“[T]he Legislature, by prescribing a sentence of life imprisonment, intends that the defendant remain in prison for the rest of his life. The term 'life' is sufficiently definite so that it can be understood and applied.”

Court's citation to Ratliff v. State, 914 So. 2d 938, 940 (Fla. 2005) in support of affirming the life sentence.

Facts & Procedural History

Curtis Edward Nowling appealed from a judgment in a criminal case from Lee County Circuit Court. The appeal concerns the validity of a life sentence i…

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Opinion of the Court

SIXTH DISTRICT COURT OF APPEAL

STATE OF FLORIDA

Case No. 6D2025-0879 Lower Tribunal No. 1990-CF-001491

CURTIS EDWARD NOWLING,

Appellant,

v.

STATE OF FLORIDA,

Appellee.

Appeal pursuant to Fla. R. App. P. 9.141(b)(2) from the Circuit Court for Lee County. Nicholas Thompson, Judge.

May 15, 2026

PER CURIAM.

AFFIRMED. See Ratliff v. State, 914 So. 2d 938, 940 (Fla. 2005) (“[T]he Legislature, by prescribing a sentence of life imprisonment, intends that the defendant remain in prison for the rest of his life. The term ‘life' is sufficiently definite so that it can be understood and applied.").

STARGEL, WOZNIAK and PRATT, JJ., concur.

Curtis Edward Nowling, Lake City, pro se.

James Uthmeier, Attorney General, Tallahassee, and Marilyn Frances Muir, Chief Assistant Attorney General, Tampa, for Appellee.


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