CHRISTOPHER DENNIS HOLTHAUS
v.
STATE OF FLORIDA
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A sentence of life imprisonment is not an illegal indefinite sentence under the Florida Constitution.
[1] A sentence of life imprisonment is sufficiently definite and does not constitute an illegal indefinite sentence under the Florida Constitution.
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Join FLexlaw to unlock all legal intelligence“The term 'life' is sufficiently definite so that it can be understood and applied, and a sentence of life imprisonment does not violate article 1, section 17”
Court's reasoning citing Ratliff v. State regarding the constitutionality of life sentences
Christopher Dennis Holthaus was convicted in St. Lucie County in 2002 and sentenced to life imprisonment. He filed a Rule 3.800 motion challenging the…
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DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA
FOURTH DISTRICT
CHRISTOPHER DENNIS HOLTHAUS, Appellant,
v.
STATE OF FLORIDA, Appellee.
No. 4D2025-1812
[September 24, 2025]
Appeal of order denying rule 3.800 motion from the Circuit Court for the Nineteenth Judicial Circuit, St. Lucie County; Michael Linn, Judge; L.T. Case No. 2002CF003677A.
Christopher D. Holthaus, Miami, pro se.
No appearance required for appellee.
PER CURIAM.
Affirmed. See Ratliff v. State, 914 So. 2d 938, 940 (Fla. 2005) (noting that “[t]he term ‘life’ is sufficiently definite so that it can be understood and applied,” and holding that “a sentence of life imprisonment does not violate article 1, section 17”); Decosta v. State, 4D2025-0682, 2025 WL 2154384, at *1 (Fla. 4th DCA July 30, 2025) (rejecting rule 3.800(a) argument alleging a life sentence was an illegal indefinite sentence).
GROSS, FORST and KLINGENSMITH, JJ., concur.
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