QUINCY JEFFERSON
v.
STATE OF FLORIDA

Fla. 4th DCA | 2025-11-05
No. 2025-2543
White, J., Levine, J., Conner, J., Forst, J.
2025 FL 10077 Florida District Court of Appeal, Fourth District (2025)

AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.


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 does not apply retroactively to cases that were final on direct appeal prior to the change.

Previewing 1 of 1 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.

Join FLexlaw to unlock all legal intelligence

Facts & Procedural History

Quincy Jefferson filed a Rule 3.800 motion in the Circuit Court for the Nineteenth Judicial Circuit, Indian River County. The trial court denied the m…

The full statement of facts, procedural history, and disposition for this case are member content.

Join FLexlaw to unlock all legal intelligence

© FLexlaw, Inc. — AI-generated enrichments are proprietary. All rights reserved.


Opinion of the Court
Forst

DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA

FOURTH DISTRICT

QUINCY JEFFERSON, Appellant,

v.

STATE OF FLORIDA, Appellee.

No. 4D2025-2543

[November 5, 2025]

Appeal of order denying rule 3.800 motion from the Circuit Court for the Nineteenth Judicial Circuit, Indian River County; Rebecca White, Judge; L.T. Case No. 312001CF000597C.

Quincy Jefferson, Avon Park, pro se.

No appearance required for appellee.

PER CURIAM.

Affirmed. See Maye v. State, 368 So. 3d 531, 532 (Fla. 6th DCA 2023), review granted, No. SC2023-1184, 2024 WL 1796831 (Fla. Apr. 25, 2024); 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).

LEVINE, CONNER and FORST, JJ., concur.

* * *


Cases With Similar Vibessemantic neighbors from the corpus


Citator

Authorities Cited

Full citator, related cases, and AI research tools

Open in FLexlaw