MICHAEL WILKES
v.
STATE OF FLORIDA
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A change in law established by Erlinger v. United States does not apply retroactively to cases on collateral review.
[1] A change in law established by Erlinger v. …
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Join FLexlaw to unlock all legal intelligenceMichael Wilkes filed a rule 3.800 motion in the Circuit Court for Broward County seeking relief from his conviction in case no. 11-740CF10A. The trial…
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DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA
FOURTH DISTRICT
MICHAEL WILKES, Appellant,
v.
STATE OF FLORIDA, Appellee.
No. 4D2025-2569
[November 19, 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. 11-740CF10A.
Michael Wilkes, Century, 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).
KUNTZ, C.J., GERBER and SHEPHERD, JJ., concur.
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Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Erlinger v. United States, 602 U.S. 821 (U.S. 2024)
- Wainwright v. State, 411 So. 3d 392 (Fla. 2025)
- Magneson v. State, 368 So. 3d 531 (Fla. 4th DCA 2024)