Maye v. State
The Florida Supreme Court held that Apprendi/Alleyne claims challenging the constitutionality of Florida's Prison Releasee Reoffender (PRR) statute are not cognizable in a Rule 3.800(a) motion to correct an illegal sentence, because such claims are subject to harmless error review and therefore cannot meet the definition of an 'illegal sentence.' The Court expressly receded from its prior decision in Plott v. State, which had held Apprendi claims were cognizable under rule 3.800(a), and affirmed denial of Maye's motion on this procedural ground without reaching the merits of whether the PRR statute is unconstitutional under Erlinger v. United States. A concurrence added that Apprendi claims challenge the sentencing process rather than the sentence itself, while a dissent argued the PRR statute is unconstitutional and that harmless error review should not bar illegal-sentence relief for Fifth/Sixth Amendment violations.
Key facts
- Maye was convicted and sentenced under Florida's Prison Releasee Reoffender (PRR) statute, and filed a Rule 3.800(a) motion to correct an illegal sentence raising an Apprendi/Alleyne constitutional challenge to the statute.
- The trial court denied the Rule 3.800(a) motion, and Maye appealed to the Florida Supreme Court.
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Why it matters
This is a major, immediately applicable precedent for Florida criminal postconviction practice: it forecloses a common avenue—Rule 3.800(a) motions—for raising Apprendi/Alleyne-based challenges to PRR, HFO, and similar… — full analysis with a trial
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