MICHAEL W. PADGETT
v.
STATE OF FLORIDA

Fla. 1st DCA | 2026-08-05
No. 2025-0980
Koberlein, Jr., J., Osterhaus, C.J., Lewis, J., Winokur, J.
2026 FL 9947 Florida District Court of Appeal, First District (2026)

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Holding

A prison releasee reoffender sentence is affirmed where any error is harmless.


Headnotes

[1] Any error in a prison releasee reoffender sentence may be deemed harmless and the sentence affirmed without deciding the constitutional impact of Erlinger v. …

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Facts & Procedural History

Padgett was convicted and sentenced as a prison releasee reoffender in Dixie County Circuit Court.…

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Opinion of the Court

FIRST DISTRICT COURT OF APPEAL

STATE OF FLORIDA

MICHAEL W. PADGETT, Appellant,

v.

STATE OF FLORIDA, Appellee.

No. 1D2025-0980

On appeal from the Circuit Court for Dixie County. Fred Koberlein, Jr., Judge.

August 5, 2026

PER CURIAM.

AFFIRMED. See Hicks v. State, 422 So. 3d 607, 608 (Fla. 1st DCA 2025) (affirming the appellant's prison releasee reoffender sentence without deciding the impact, if any, of Erlinger v. United States, 602 U.S. 821 (2024), because any error was harmless); Alonso v. State, 415 So. 3d 826, 827 (Fla. 2d DCA 2025) (same); Ashford v. State, 407 So. 3d 537, 537 (Fla. 5th DCA 2025) (same).

OSTERHAUS, C.J., and LEWIS and WINOKUR, JJ., concur.


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