TIMOTHY HARTMAN
v.
STATE OF FLORIDA
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A change in law established by Erlinger v. United States does not apply retroactively to cases already final on direct appeal.
[1] A change in law does not apply retroactively to criminal cases that were final on direct appeal prior to the change.
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Join FLexlaw to unlock all legal intelligenceTimothy Hartman filed a rule 3.800 motion in a criminal case from 2002. The trial court denied the motion.…
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DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA
FOURTH DISTRICT
TIMOTHY HARTMAN, Appellant,
v.
STATE OF FLORIDA, Appellee.
No. 4D2025-0977
[July 2, 2025]
Appeal of order denying rule 3.800 motion from the Circuit Court for the Seventeenth Judicial Circuit, Broward County; Thomas J. Coleman, Judge; L.T. Case No. 02-006875-CF10A.
Timothy Hartman, Blountstown, pro se.
No appearance required for appellee.
PER CURIAM.
Affirmed. See Wainwright v. State, 2025 WL 1561151, at *5 (Fla. 2025) (even if Erlinger v. United States, 602 U.S. 821 (2024), constitutes a change of law, it does not apply retroactively).
CIKLIN, GERBER and CONNER, JJ., concur.
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