Matthew Dettle v. State
The Florida Supreme Court answered a certified question of great public importance, holding that its 2018 decision in Lee v. State—which requires courts to look only to the charging document (not the evidentiary record) to determine whether multiple convictions for solicitation, traveling after solicitation, and use of a two-way communications device violate double jeopardy—does not apply retroactively to convictions that were already final when Lee was decided. The Court reached this conclusion under both the state Witt retroactivity standard and the federal Teague standard, finding Lee to be a procedural 'evolutionary refinement' rather than a substantive 'jurisprudential upheaval' or watershed rule. Two justices concurred specially, one criticizing the majority's reliance analysis and both urging the Court to revisit and potentially overhaul the Witt retroactivity framework in a future case.
Key facts
- Defendants were convicted of solicitation of a minor, traveling after solicitation, and use of a two-way communications device in connection with the solicitation.
- The trial court convicted defendants based on charges alleging these three offenses arose from the same conduct.
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Why it matters
This decision resolves a recurring postconviction issue for defendants convicted of the trio of child-solicitation-related offenses (§§ 847.0135(3)-(4), 934.215) whose convictions became final before Lee (2018): they… — full analysis with a trial
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