Ranne v. State
The Fourth DCA held that a trial court exceeded the statutory maximum when it selected a 25-year mandatory minimum under the 10-20-life statute but then imposed a total sentence of life for attempted second-degree murder with a firearm, a first-degree felony carrying a 30-year maximum. Because the court chose 25 years as the 10-20-life component rather than life itself, it lacked independent statutory authority to impose a longer total sentence. The court also ordered correction of a scrivener's error in the written cost order that did not match the $100 orally pronounced prosecution fee.
Key facts
- Defendant was convicted of attempted second-degree murder with a firearm and sentenced to 25 years as a mandatory minimum under the 10-20-life statute, with a total sentence of life imprisonment.
- The trial court imposed a life sentence as the total sentence despite selecting 25 years (rather than life) as the mandatory minimum component under the 10-20-life statute.
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Why it matters
This opinion reinforces and applies the Hatten/Garnes framework governing the interplay between the 10-20-life statute and the general statutory maximum, a recurring trap for trial courts that select a term-of-years… — full analysis with a trial
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