Hutchinson v. State
The Second District reversed the denial of Hutchinson's rule 3.800(a) motion challenging his prison releasee reoffender (PRR) sentence, holding that the postconviction court misapplied State v. Lewars. Even though Hutchinson had initially been sentenced to and served time in a Florida Department of Corrections facility, because he was physically released from a county jail (not a DOC or private vendor facility), he did not qualify as a PRR under the statute's plain language.
Key facts
- Hutchinson was sentenced as a prison releasee reoffender (PRR) after initially serving time in a Florida Department of Corrections facility, but was later transferred to and physically released from a county jail.
- The postconviction court denied Hutchinson's rule 3.800(a) motion challenging his PRR sentence, finding he qualified under the statute despite his release from a county jail rather than a DOC or private prison facility.
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Why it matters
This decision clarifies that Lewars' holding on PRR qualification is not limited to defendants who were never housed in a DOC facility—it applies broadly whenever the defendant's actual physical release occurred from a… — full analysis with a trial
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