Soto v. State
The Fourth District addressed whether Erlinger v. United States requires a jury, rather than a judge by preponderance of evidence, to find the facts necessary for a prison releasee reoffender (PRR) sentence. The court held that even assuming the issue was preserved and that Erlinger applies, any error was harmless because the defendant never disputed that he in fact qualified as a PRR (i.e., his release date and qualifying offense were undisputed ministerial matters).
Key facts
- Defendant Soto, a prison releasee reoffender (PRR), was sentenced by the trial judge based on judicial findings of facts necessary for PRR enhancement.
- Soto challenged his sentence via Rule 3.800(b)(2) motion, arguing that Erlinger v. United States requires a jury, not a judge, to find the facts necessary for PRR sentencing.
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Why it matters
This opinion is useful to practitioners litigating post-Erlinger challenges to Florida's PRR and HFO enhancement statutes, a rapidly recurring issue since the 2024 SCOTUS decision. It confirms the Fourth District's… — full analysis with a trial
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