Lewis v. State
The Fourth DCA affirmed denial of a rule 3.800(a) motion challenging a 35-year sentence with a 25-year 10-20-Life mandatory minimum for attempted robbery, holding that under Earl v. State the defendant could not show prejudice because the sentence was actually more lenient than the life-mandatory-minimum the court could have legally imposed. The court expressly rejected the State's concession that the sentence was illegal under Hatten v. State, and certified conflict with the Fifth DCA's Ray and Perez decisions, which had granted 3.800(a) relief on nearly identical facts without addressing Earl. Judge Warner dissented, arguing Earl does not apply where the requested relief would reduce (not increase) the defendant's sentence, and that the excess portion of the sentence remains illegal and correctable under Hatten, Garnes, and Wynn.
Key facts
- Defendant Lewis was convicted of attempted robbery and sentenced to 35 years with a mandatory 25-year 10-20-Life minimum.
- Lewis filed a rule 3.800(a) motion challenging the legality of his sentence, arguing it violated the 10-20-Life statute as interpreted in Hatten v. State.
- +2 more key facts with a free trial
Why it matters
This opinion creates an explicit and acknowledged district split on a recurring 10-20-Life sentencing issue affecting potentially many postconviction motions statewide, making it a strong candidate for further review by… — full analysis with a trial
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