MARCO PACE
v.
THE STATE OF FLORIDA

Fla. 3d DCA | 2023-06-21
No. 23-0017
Florida District Court of Appeal, Third District (2023)

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Holding

Collateral estoppel, or issue preclusion, applies to motions filed under Florida Rule of Criminal Procedure 3.800, preventing relitigation of issues already decided in prior proceedings.


Headnotes

[1] Collateral estoppel, or issue preclusion, applies to motions filed under Florida Rule of Criminal Procedure 3.800 to correct an illegal sentence, preventing a defendant f…

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Key Quotes

“Although res judicata may not apply to motions filed under rule 3.800, the similar, but more narrow, doctrine of collateral estoppel, or issue preclusion, does apply.”

From State v. McBride, cited for the proposition that collateral estoppel applies to Rule 3.800 motions

Facts & Procedural History

Marco Pace appealed from decisions in two criminal cases (F98-36722 and F99-4398) in Miami-Dade County Circuit Court, raising claims in a motion under…

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Opinion of the Court

PER CURIAM.

Affirmed. See State v. McBride, 848 So. 2d 287, 290 (Fla. 2003) (“Although res judicata may not apply to motions filed under rule 3.800, the similar, but more narrow, doctrine of collateral estoppel, or issue preclusion, does apply.”); Ali v. State, 911 So. 2d 164, 166 (Fla. 3d DCA 2005) (“[T]he trial court correctly denied the defendant’s claim regarding lack of notice as this claim may not be raised in a motion to correct an illegal sentence pursuant to Florida Rule of Criminal Procedure 3.800 . . . .”).

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