JEFFREY HARRELL
v.
STATE OF FLORIDA

Fla. 4th DCA | 2025-10-15
No. 2025-2292
Fein, J., May, J., Levine, J., Conner, J.
2025 FL 9083 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 already final on direct appeal.


Headnotes

[1] A change in law established by subsequent appellate decision does not apply retroactively to cases that were final on direct appeal prior to the change.

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Facts & Procedural History

Jeffrey Harrell filed a Rule 3.800 motion in the Circuit Court for Broward County seeking relief from his conviction. The trial court denied the motio…

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Opinion of the Court
Conner

DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA

FOURTH DISTRICT

JEFFREY HARRELL, Appellant,

v.

STATE OF FLORIDA, Appellee.

No. 4D2025-2292

[October 15, 2025]

Appeal of order denying rule 3.800 motion from the Circuit Court for the Seventeenth Judicial Circuit, Broward County; Martin S. Fein, Judge; L.T. Case No. 17-13965CF10A.

Jeffrey Harrell, Bushnell, pro se.

No appearance required for appellee.

PER CURIAM.

Affirmed. See Wainwright v. State, 411 So. 3d 392 (Fla. 2025) (holding that even if Erlinger v. United States, 602 U.S. 821 (2024), constitutes a change of law, it does not apply retroactively).

MAY, LEVINE and CONNER, JJ., concur.

* * *


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