HERMAN T. WILLIAMS
v.
STATE OF FLORIDA

Fla. 4th DCA | 2025-09-03
No. 2025-1659
Usan, J., Gross, J., Gerber, J., Levine, J.
2025 FL 7643 Florida District Court of Appeal, Fourth District (2025)

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Holding

A change in law established by Erlinger v. United States does not apply retroactively to cases that were final when the decision was issued.


Headnotes

[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 issued.

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Key Quotes

“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”

Court's rationale for affirming denial of rule 3.800 motion

Facts & Procedural History

Herman Williams appealed the denial of his rule 3.800 motion in a criminal case from Broward County.…

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Opinion of the Court
Levine

DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA

FOURTH DISTRICT

HERMAN WILLIAMS, Appellant,

v.

STATE OF FLORIDA, Appellee.

No. 4D2025-1659

[September 3, 2025]

Appeal of order denying rule 3.800 motion from the Circuit Court for the Seventeenth Judicial Circuit, Broward County; Michael A. Usan, Judge; L.T. Case No. 17-10037CF10A.

Herman Williams, Malone, pro se.

No appearance required for appellee.

PER CURIAM.

Affirmed. See Wainwright v. State, 411 So. 3d 392, 401 (Fla. 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).

GROSS, GERBER and LEVINE, JJ., concur.

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