MICHAEL MERCHISON
v.
STATE OF FLORIDA

Fla. 3d DCA | 2026-01-14
No. 2025-2000
Stuzin, J., Gordo, J., Lobree, J., Gooden, J.
2026 FL 476 Florida District Court of Appeal, Third District (2026)

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Holding

A claimed legal error does not apply retroactively to the appellant's conviction or sentence.


Headnotes

[1] A claimed legal error that has been held not to apply retroactively by the Florida Supreme Court cannot serve as a basis for postconviction relief.

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Key Quotes

“Erlinger does not apply retroactively.”

Wainwright v. State, 411 So. 3d 392, 401 (Fla. 2025)

Facts & Procedural History

Michael Merchison appealed from a circuit court order in Miami-Dade County. The appeal involved a claim of legal error that the appellant argued shoul…

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Opinion of the Court
Gooden

Third District Court of Appeal State of Florida

Opinion filed January 14, 2026. Not final until disposition of timely filed motion for rehearing.

________________

No. 3D25-2000 Lower Tribunal No. F05-9849 ________________

Michael Merchison, Appellant,

vs.

State of Florida, Appellee.

An Appeal under Florida Rule of Appellate Procedure 9.141(b)(2) from the Circuit Court for Miami-Dade County, Laura Anne Stuzin, Judge.

Michael Merchison, in proper person.

James Uthmeier, Attorney General, and Daihana Chang, Assistant Attorney General, for appellee.

Before GORDO, LOBREE, and GOODEN, JJ.

PER CURIAM.

2 Affirmed. See Wainwright v. State, 411 So. 3d 392, 401 (Fla. 2025) (“Erlinger does not apply retroactively.”); Arias v. State, 413 So. 3d 999 (Fla. 3d DCA 2025) (“Observing that the purported error was unpreserved and is not apparent on the face of the record, and even more significantly, no Court of Appeals, let alone the Supreme Court, has held that Apprendi has retroactive effect, and the Florida Supreme Court has rejected this ground for relief in at least two reported postconviction cases, we affirm the order under review in all respects.”) (citation modified).


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