MARK S. BROWN
v.
STATE OF FLORIDA

Fla. 6th DCA | 2026-07-02
No. 2025-1308
Branning, J., Nardella, J., White, J., Kamoutsas, J.
2026 FL 8321 Florida District Court of Appeal, Sixth District (2026)

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Holding

A sentence of life imprisonment is sufficiently definite under Florida law and means the defendant shall remain in prison for the rest of his life.


Headnotes

[1] A sentence of life imprisonment prescribed by the Legislature is sufficiently definite as a matter of law and means the defendant shall remain in prison for the rest of h…

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Key Quotes

“[T]he Legislature, by prescribing a sentence of life imprisonment, intends that the defendant remain in prison for the rest of his life. The term 'life' is sufficiently definite so that it can be understood and applied.”

Court's citation to Ratliff v. State in affirming the sentence

Facts & Procedural History

Mark S. Brown was convicted and sentenced to life imprisonment in Lee County Circuit Court. He appealed the sentence.…

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Opinion of the Court

SIXTH DISTRICT COURT OF APPEAL

STATE OF FLORIDA

Case No. 6D2025-1308 Lower Tribunal No. 1994-CF-002120

MARK S. BROWN,

Appellant,

v.

STATE OF FLORIDA,

Appellee.

Appeal pursuant to Fla. R. App. P. 9.141(b)(2) from the Circuit Court for Lee County. Robert Branning, Judge.

July 2, 2026

PER CURIAM.

AFFIRMED. See Ratliff v. State, 914 So. 2d 938, 940 (Fla. 2005) (“[T]he Legislature, by prescribing a sentence of life imprisonment, intends that the defendant remain in prison for the rest of his life. The term 'life' is sufficiently definite so that it can be understood and applied.").

NARDELLA, WHITE and KAMOUTSAS, JJ., concur.

Mark S. Brown, Mayo, pro se.

James Uthmeier, Attorney General, Tallahassee, and Marilyn Frances Muir, Chief Assistant Attorney General, Tampa, for Appellee.


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