Hill v. State
The First DCA held that when the State declines to seek a PRR (prison releasee reoffender) sentence at original sentencing and instead agrees to a guidelines sentence with probation, it cannot later seek the PRR enhancement upon revocation of that probation. Applying Mack v. State, the court found the enhancement decision was 'completed' at original sentencing and could not be revisited later, vacating the mandatory life PRR sentence imposed on revocation and remanding for discretionary sentencing.
Key facts
- Hill was sentenced to a guidelines term with probation after the State declined to seek a PRR (prison releasee reoffender) enhancement at original sentencing.
- Upon revocation of Hill's probation, the trial court imposed a mandatory life PRR sentence, believing it had no discretion in the matter.
- +2 more key facts with a free trial
Why it matters
This decision reinforces and applies the Mack v. State rule limiting the State's ability to seek habitual/enhanced sentencing designations after previously forgoing them at original sentencing, extending that logic… — full analysis with a trial
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