WILLIAM FITZGERALD SEWARD
v.
STATE OF FLORIDA

Fla. 5th DCA | 2026-07-24
No. 2025-3057
Hatcher, J., Jay, C.J., Eisnaugle, J., MacIver, J.
2026 FL 9514 Florida District Court of Appeal, Fifth District (2026)

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Holding

When a postconviction court denies a Rule 3.800(a) motion challenging the legality of a sentence, the appellate record must conclusively demonstrate the defendant is entitled to no relief, and ambiguities regarding the sentencing scoresheet warrant reversal and remand.


Headnotes

[1] When reviewing a postconviction court's denial of a Rule 3.800(a) motion challenging sentence legality, the appellate record must conclusively demonstrate the defendant i…

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Key Quotes

“But our record in this case does not conclusively show that Seward is 'entitled to no relief.'”

Court's explanation for reversal based on the appellate standard under Fla. R. App. P. 9.141(b)(2)(D)

Facts & Procedural History

William Fitzgerald Seward received a twenty-year sentence for manslaughter with a firearm. He filed a Rule 3.800(a) motion alleging the sentence was i…

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Opinion of the Court

FIFTH DISTRICT COURT OF APPEAL

STATE OF FLORIDA

Case No. 5D2025-3057 LT Case No. 2017-CF-000141-A

WILLIAM FITZGERALD SEWARD, Appellant,

V.

STATE OF FLORIDA, Appellee.

3.800 Appeal from the Circuit Court for Sumter County. Mary Pavloff Hatcher, Judge.

William Fitzgerald Seward, Perry, pro se.

James Uthmeier, Attorney General, Tallahassee, and Alyssa M. Williams, Assistant Attorney General, Daytona Beach, for Appellee.

July 24, 2026

PER CURIAM.

William Fitzgerald Seward appeals the denial of his Florida Rule of Criminal Procedure 3.800(a) motion alleging that the twenty-year sentence he received for manslaughter with a firearm is illegal. The postconviction court denied the motion, reasoning that Seward's scoresheet authorized a twenty-year sentence. While the lowest permissible sentence must be imposed when it

exceeds the statutory maximum, section 921.0024(2), Florida Statutes (2017), Seward's scoresheet reflects that his lowest permissible sentence falls well below the statutory maximum for manslaughter with a firearm.1

We express no opinion concerning the merits of the motion. But our record in this case does not conclusively show that Seward is "entitled to no relief.” Fla. R. App. P. 9.141(b)(2)(D). We therefore reverse and remand for further proceedings.

REVERSED and REMANDED.

JAY, C.J., and EISNAUGLE and MACIVER, JJ., concur.


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