ANTHONY SANCHEZ
v.
STATE OF FLORIDA

Fla. 3d DCA | 2025-07-02
No. 2025-0652
Scales, C.J., Emas, J., Gooden, J., Areces, J.
2025 FL 5568 Florida District Court of Appeal, Third District (2025)

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Holding

A life sentence is sufficiently definite under the Constitution and does not become indefinite based on uncertainty regarding a defendant's life expectancy.

Headnotes

[1] A sentence of life imprisonment is not unconstitutionally indefinite under the Florida Constitution or the United States Constitution merely because the judicial system c…

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Key Quotes

“The term 'life' is sufficiently definite so that it can be understood and applied.”

From Ratliff v. State, cited for the proposition that life sentences are not unconstitutionally indefinite.
Facts & Procedural History

Anthony Sanchez appealed a sentence imposed by the Circuit Court for Miami-Dade County. The appeal challenged the constitutionality of the sentence im…

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Opinion of the Court
Scales

Third District Court of Appeal State of Florida

Opinion filed July2, 2025. Not final until disposition of timely filed motion for rehearing.

________________

No. 3D25-0652 Lower Tribunal No. F09-32944 ________________

Anthony Sanchez, Appellant,

vs.

State of Florida, Appellee.

An Appeal under Florida Rule of Appellate Procedure 9.141(b)(2) from the Circuit Court for Miami-Dade County, Ramiro C. Areces, Judge.

Anthony Sanchez, in proper person.

James Uthmeier, Attorney General, and Haccord J. Curry, Assistant Attorney General, for appellee.

Before SCALES, C.J., and EMAS and GOODEN, JJ.

PER CURIAM.

Footnotes
2 Affirmed. See Ratliff v. State, 914 So. 2d 938, 940 (Fla. 2005) (“[A]ny sentence, even one of a short duration, can potentially exceed a defendant’s life span. The fact that the judicial system has no way of knowing how long the defendant will live and therefore cannot know how long the defendant will be incarcerated does not render a life sentence unconstitutionally indefinite. It is abundantly clear that the 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.” (internal citations omitted)); Alvarez v. State, 358 So. 2d 10, 12 (Fla. 1978) (“We reject the notion that an individual’s life expectancy should be used, or was intended by the Legislature to be used, to mark the longest term which a particular defendant should serve. Any sentence, no matter how short, may eventually extend beyond the life of a prisoner.”); Simmons v. State, No. 3D25-0655, 2025 WL 1700091, at *1 (Fla. 3d DCA June 18, 2025); Alvarez v. State, No. 3D25-0533, 2025 WL 1509636, at *1 (Fla. 3d DCA May 28, 2025); Jimenez-Solano v. State, No. 3D25-374, 2025 WL 1509570, at *1 (Fla. 3d DCA May 28, 2025); Lemon v. State, No. 3D25-0535, 2025 WL 1450561, at *1 (Fla. 3d DCA May 21, 2025); Padgett v. State, No. 3D25-0349, 2025 WL 1172840, at *1 (Fla. 3d DCA Apr. 23, 2025); Holmes v. State, 245 So. 3d 857, 858 (Fla. 3d DCA 2018);
3 Johnson v. Crosby, 897 So. 2d 546, 547 (Fla. 3d DCA 2005); Lopez v. State, 895 So. 2d 1282, 1282 (Fla. 3d DCA 2005); Enriquez v. State, 885 So. 2d 892, 892 (Fla. 3d DCA 2004).

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