KENNETH WILLINGHAM
v.
STATE OF FLORIDA
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A change in law established by Erlinger v. United States does not apply retroactively to cases that were final before the decision was rendered.
[1] A change in law established by a United States Supreme Court decision does not apply retroactively to criminal cases that became final before the decision was rendered.
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Join FLexlaw to unlock all legal intelligenceKenneth Willingham appealed an order denying his Rule 3.800 motion in a criminal case from Palm Beach County.…
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DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA
FOURTH DISTRICT
KENNETH WILLINGHAM, Appellant,
v.
STATE OF FLORIDA, Appellee.
No. 4D2025-0160
[July 16, 2025]
Appeal of order denying rule 3.800 motion from the Circuit Court for the Fifteenth Judicial Circuit, Palm Beach County; Cymonie S. Rowe, Judge; L.T. Case No. 502017CF007320A.
Kenneth Willingham, Wewahitchka, pro se.
No appearance required for appellee.
PER CURIAM.
Affirmed. See Wainwright v. State, No. SC2025-0708, 2025 WL 1561151 (Fla. June 3, 2025) (holding that, even if Erlinger v. United States, 602 U.S. 821 (2024), constitutes a change in law, it does not apply retroactively to cases that were final when it was decided).
KUNTZ, C.J., CIKLIN and FORST, JJ., concur.
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