Reeves v. State
The Sixth DCA affirmed a PRR sentencing enhancement for a conviction of burglary of a conveyance with an assault and a battery, holding under State v. Hackley that courts look to the offense of conviction—not the charged offense—to determine PRR eligibility under the catch-all provision. Because the defendant's conviction necessarily included burglary of a conveyance with an assault (a qualifying offense under Hackley), the enhancement was proper even though a battery alone would not qualify. A specially concurring judge went further, arguing burglary itself is independently a qualifying PRR offense via incorporation of the forcible felony statute's catch-all provision, and would have certified direct conflict with seven sister-district decisions (Smith, Crosley, Suffield, Santiago, Wilson, Williams, Gorham).
Key facts
- Defendant was convicted of burglary of a conveyance with an assault and a battery in the trial court.
- The trial court imposed a PRR sentencing enhancement based on the conviction.
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Why it matters
This case is significant because it squarely resolves, for the first time in the Sixth DCA, how the PRR catch-all provision applies to burglary-of-a-conveyance-with-assault-and-battery convictions, confirming that… — full analysis with a trial
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