Munden v. State
The Fourth DCA reversed Munden's sentence on attempted first-degree murder because his Prison Releasee Reoffender (PRR) designation was an ex post facto violation—he was released from a county jail, not a state DOC facility, under the pre-2019 version of the PRR statute as construed in State v. Lewars—and because the trial court impermissibly designated him as both an HFO and HVFO on the same count in violation of Clines v. State. The court also remanded Count 2 to impose the mandatory minimum firearm enhancement the trial court had erroneously omitted, ordered a corrected scoresheet, and directed correction of scrivener's errors so the written sentence conforms to the oral pronouncement.
Key facts
- Munden was convicted of attempted first-degree murder and other offenses and sentenced as a Prison Releasee Reoffender (PRR) with both Habitual Felony Offender (HFO) and Habitual Violent Felony Offender (HVFO) designations on the same count.
- The trial court failed to impose a mandatory minimum firearm enhancement on Count 2 and the written sentencing order contained discrepancies from the oral pronouncement.
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Why it matters
This opinion is a useful practical guide for challenging stacked recidivist enhancements and PRR designations based on release location, reaffirming that release from a county jail (rather than a state DOC facility)… — full analysis with a trial
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