Landrum v. State
On resentencing of a juvenile offender convicted of second-degree murder, the circuit court recognized that the jury's verdict did not include the Alleyne finding of whether Landrum actually killed, intended to kill, or attempted to kill the victim, but then made that finding itself and imposed a life sentence with twenty-five-year review. The Second District held this was error because the resentencing court applied the appellate harmless-error standard rather than simply imposing the shorter fifteen-year review period required absent a jury finding, reversing and remanding for de novo resentencing.
Key facts
- Landrum, a juvenile offender, was convicted of second-degree murder and resentenced by the circuit court, which found that Landrum actually killed, intended to kill, or attempted to kill the victim and imposed a life sentence with a twenty-five-year review period.
- The jury's original verdict did not include the Alleyne finding regarding whether Landrum actually killed, intended to kill, or attempted to kill the victim.
- +2 more key facts with a free trial
Why it matters
This opinion gives juvenile-offender sentencing practitioners a clear, citable rule that trial courts may not substitute their own harmless-error analysis for a missing jury finding on actual/intended/attempted killing… — full analysis with a trial
🔒 Read the full opinion, holding & search the library
The full opinion PDF, the rules the court applied, our significance analysis, the background facts, and full-text search across every tracked Florida decision are available to members. Start a free 30-day trial — no credit card.
Not ready to sign up? Get the free Friday digest — the week's key Florida decisions by email, no login required.
Florida Court Tracker provides summaries of publicly available court opinions for informational and research purposes only. This is not legal advice and does not create an attorney–client relationship. Always verify holdings against the official opinion.