Renardo Scott v. State of Florida
The Third DCA affirmed the revocation of Scott's probation and his sentencing to mandatory life as a Prison Release Reoffender (PRR) after revocation, even though the State had waived PRR designation at the original 2008 sentencing in exchange for a plea. The court held that Scott's probationary term was properly tolled during his unrelated concurrent incarceration in Broward County, and that under Foulks v. State, the State may seek a PRR sentence upon revocation despite having waived it originally, so long as the defendant qualified as PRR at the time of initial sentencing. The court also held the PRR determination is 'administerial' and does not require jury findings, rejecting an Erlinger-based Sixth Amendment challenge, but expressly certified conflict with the First DCA's contrary holding in Hill v. State.
Key facts
- Renardo Scott's probation was revoked, and he was sentenced to mandatory life as a Prison Release Reoffender (PRR), even though the State had waived PRR designation at his original 2008 sentencing in exchange for his guilty plea.
- Scott had served concurrent incarceration in Broward County on an unrelated sentence during his probationary term, and the trial court tolled his probation period during that incarceration.
- +2 more key facts with a free trial
Why it matters
This opinion is highly significant because it creates an express, acknowledged certified conflict between the Third DCA (Foulks/Duggans/Scott line) and the First DCA (Hill) on whether the State can obtain a PRR… — full analysis with a trial
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