Maye v. State
The Florida Supreme Court held that Apprendi/Alleyne claims—challenging a judge's rather than a jury's factual finding that increases a mandatory minimum sentence—are not cognizable as 'illegal sentence' claims under Florida Rule of Criminal Procedure 3.800(a), because such claims are subject to harmless error review and thus cannot meet the 'illegal sentence' standard. The Court expressly receded from Plott v. State, 148 So. 3d 90 (Fla. 2014), which had held such claims cognizable under 3.800(a), and affirmed denial of Maye's motion challenging his PRR-based mandatory life sentence on this procedural ground without reaching the underlying constitutional merits (which the State conceded were meritorious under Erlinger v. United States). Justice Labarga dissented, arguing the PRR statute is unconstitutional and that harmless error review has no place in Apprendi analysis.
Key facts
- Defendant Maye was sentenced to mandatory life imprisonment based on a judicial finding under Florida's Prison Release Restitution (PRR) statute that increased his mandatory minimum sentence.
- Maye filed a motion under Florida Rule of Criminal Procedure 3.800(a) challenging his sentence as illegal, arguing the judicial fact-finding that enhanced his sentence violated Apprendi and Alleyne principles.
- +2 more key facts with a free trial
Why it matters
This is a major precedent-shifting decision for Florida criminal postconviction practice: it forecloses a common avenue defendants have used for over a decade to raise Apprendi/Alleyne sentencing-enhancement challenges… — full analysis with a trial
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