ROBERT E. ROWLES
v.
STATE OF FLORIDA

Fla. 6th DCA | 2026-06-05
No. 2025-2803
Kyle, J., Smith, J., Mize, J., Kamoutsas, J.
2026 FL 6878 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 prescribed by the Legislature is sufficiently definite as a matter of law and constitutes a valid sentence.

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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 in support of affirming the life sentence

Facts & Procedural History

Robert E. Rowles appealed from a judgment in a criminal case from Lee County Circuit Court. The appeal concerns the validity of a life sentence impose…

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Opinion of the Court

SIXTH DISTRICT COURT OF APPEAL

STATE OF FLORIDA

Case No. 6D2025-2803 Lower Tribunal No. 2011-CF-014131

ROBERT E. ROWLES,

Appellant,

v.

STATE OF FLORIDA,

Appellee.

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

June 5, 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.").

SMITH, MIZE and KAMOUTSAS, JJ., concur.

Robert E. Rowles, Miami, pro se.

James Uthmeier, Attorney General, Tallahassee, and Cerese Crawford Taylor, Chief Assistant Attorney General, Tampa, for Appellee.


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