Coullias v. State
The First DCA held that a DUI manslaughter sentence of the statutory maximum fifteen years' imprisonment, without any accompanying probationary period allowing completion of a substance-abuse course, is illegal under section 316.193(5), Florida Statutes. Aligning with the Second and Fourth Districts (Archer and Powers), the panel reversed and remanded for de novo resentencing, and, per the majority and concurrence, certified a question of great public importance to the Florida Supreme Court asking whether section 316.193(5)'s probation/course requirements limit a trial court's ability to impose the full fifteen-year maximum under section 775.082. Judge Tanenbaum dissented at length, arguing the sentence was lawful under the statutory maximum and that the majority impermissibly created a judicially enforceable right to probation absent any constitutionally cognizable harm.
Key facts
- Defendant was convicted of DUI manslaughter and sentenced by the trial court to fifteen years' imprisonment, the statutory maximum, with no accompanying probationary period.
- The First District Court of Appeal reviewed whether a maximum fifteen-year DUI manslaughter sentence without a qualifying probationary term allowing completion of a substance-abuse course complies with section 316.193(5), Florida Statutes.
- +2 more key facts with a free trial
Why it matters
This opinion resolves a recurring DUI manslaughter sentencing issue by aligning the First DCA with the Second and Fourth Districts (Archer, Powers), giving practitioners statewide precedent that a maximum fifteen-year… — full analysis with a trial
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