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**The “Cite” of the Crime**

The “Cite of the Crime” Podcast is a biweekly Florida and Federal criminal case law update show for criminal defense attorneys, prosecutors, judges and anybody who is interested in criminal law case law in the Florida District Courts, the Florida Supreme Court, the Eleventh Circuit Court of Appeals and the U.S. Supreme Court. Each week, criminal defense attorney, Jeremy Lasnetski of Shorstein, Lasnetski, & Gihon reviews the previous weeks Florida DCA and Florida Supreme Court cases and in a separate weekly federal episode, reviews the previous weeks Eleventh Circuit and U.S. Supreme Court criminal cases. Join us at The “Cite” of the Crime during your commute, jog, or any other time to keep up to date on the latest criminal court opinions.

Latest Episodes:

Episode #14: Federal Criminal Case Law Update (September 26, 2022 - September 30, 2022) Oct 05, 2022

Show notes

EPISODE #14: Federal Criminal Case Law Update (9/29/22 - 9/30/22)

Case #1 - USA v. Conage (9/30/22) - 00:59 - Whether Florida’s Trafficking qualifies as an ACCA predicate offense.

Case #2 - Azmat v. USA (9/28/22) - 3:07 - Successive 2255 motion case.

Case #3 - Cesal v. USA (9/29/22) - 4:50 - Successive §2255 motion case.

Case #4 - Johnson v. USA (9/27/22) - 9:40 - §2255 equitable tolling case.

Case #5 - USA v. Chapman (9/30/22) - 11:58 - Sufficiency of the evidence case.

Case #6 - USA v. Coney (9/28/22 ) - 15:59 - Appeal waiver case.

Case #7 - USA v. Gissendanner (9/28/22) - 18:41 - Batson juror strike case.

Case #8 - USA v. Goodman (9/28/22) - 26:13 - Sup. Rel. Rev. Case

Case #9 - USA v. Lutin (9/28/22) - 28:00 - Upward variance case.

Case #10 - USA v. Ravelo (9/28/22) - 31:00 - Motion to withdraw plea case.

Case #11 - USA v. Reyes (9/27/22)- 35:21 - Restitution order case.

Case #12 - USA v. Turner (9/29/22) - 37:31 - Traffic stop suppression case

Case #13 - USA v. Valencia (9/30/22) - 44:11 - MDLEA case
Compassionate Release Cases:Anderson ; Erwin; Moss

Episode #13 - Florida Criminal Case Law Update (September 26, 2022 - September 30, 2022) Oct 03, 2022

Show notes

EPISODE: #13: Florida Criminal Case Law Update (September 26, 2022 - September 30, 2022)

OVERVIEW - 6 Cases

1 - Florida Supreme Court Cases
3 - First DCA Cases
0 - Second DCA Cases
1 - Third DCA Cases
1 - Fourth DCA Cases
0 - Fifth DCA Cases

Case #1 - Truehill v. State, SC20-1589 (Fla. Sup. Ct.)(September 29, 2022) - 1:19

Truehill is a 3.851 ineffective assistance of counsel after a death sentence case.

Case #2 - Herring v. State, No. 1D20-0861 (Fla. 1st DCA)(September 28, 2022) - 12:17

Herring is a probation revocation case out of Liberty County.

Case #3 - Jordan v. State, No. 1D22-2960 (Fla. 1st. DCA)(September 27, 2022) - 13:56

Jordan is a Motion to Withdraw by the public defender case.

Case #4 - Parrish v. State, No. 1D21-1435 (Fla. 1st DCA)(September 28, 2022) - 17:12

Parrish is a sex offense sentencing case out of Escambia County.

Case #5 - T.T.W. v. State, No. 3D21-1045 (Fla. 3rd DCA)(September 30, 2022) - 20:12

T.T.W. is a Juvenile adjudicatory hearing case involving Zoom testimony.

Case #6 - Johnstone v. State, No. 4D21-1411 (Fla. 4th DCA)(September 30, 2022) - 21:18

Johnstone is a stalking case out of Okeechobee County.

Episode #12 - Federal Criminal Case Law Update - (September 19, 2022 - September 23, 2022) Sep 28, 2022

Show notes

EPISODE :#12: Federal Case Law Update (9/19/22 - 9/23/22)

OVERVIEW

14 cases
1 published decisions
13 unpublished decisions

Case # 1 - USA v. Grushko, No. 20-10438 (11th Cir. pub. Dec.)(September 23, 2022) - 1:00

https://media.ca11.uscourts.gov/opinions/pub/files/202010438.pdf

Case #2 - USA v. Beckford, No. 22-10638 (11th Cir. Unpub. Dec.)(September 22, 2022) - 13:08

https://media.ca11.uscourts.gov/opinions/unpub/files/202210638.pdf

Case #3 - USA v. Bennett, No. 21-11599 (11th Cir. Unpub. Dec.)(September 19, 2022) - 15:04

https://media.ca11.uscourts.gov/opinions/unpub/files/202111599.pdf

Case #4 - USA v. Billups, No. 22-10331 (11th Cir. Unpub. Dec.)(September 20, 2022) - 18:01

https://media.ca11.uscourts.gov/opinions/unpub/files/202210331.pdf

Case #5 - USA v. Cargill, No. 20-13507 (11th Cir. Unpub. Dec.)(September 22, 2022) - 19:39

https://media.ca11.uscourts.gov/opinions/unpub/files/202013507.pdf

Case #6 - USA v. Denson, No. 21-11077 (11th Cir. Unpub. Dec.)(September 21, 2022) - 27:19

https://media.ca11.uscourts.gov/opinions/unpub/files/202111077.pdf

Case #7 - USA v. Frank, No.. 20-11049 (11th Cir. Unpub. Dec.)(September 21, 2022) - 28:14

https://media.ca11.uscourts.gov/opinions/unpub/files/202011049.pdf

Case #8 - USA v. Greenberg, No. 21-12940 (11th Cir. Unpub. Dec.)(September 19, 2022) - 35:12

https://media.ca11.uscourts.gov/opinions/unpub/files/202112940.pdf

Case #9 - USA v. Harrington, No. 21-13404 (11th Cir. Unpub. Dec.)(September 21, 2022) - 36:15

https://media.ca11.uscourts.gov/opinions/unpub/files/202113404.pdf

Case #10 - USA v. Madison, No.21-12611 (11th Cir. Unpub. Dec.)(September 19, 2022) - 37:14

https://media.ca11.uscourts.gov/opinions/unpub/files/202112611.pdf

Case #11 - USA v. McCary, No. 21-12807 (11th Cir. Unpub. Dec.)(September 21, 2022) - 38:47

https://media.ca11.uscourts.gov/opinions/unpub/files/202112807.pdf

Case #12 - USA v. Mike, No. 21-13700 (11th Cir. Unpub. Dec.)(September 22, 2022) - 40:41

https://media.ca11.uscourts.gov/opinions/unpub/files/202113700.pdf

Case #13 - USA v. Quiroga, No. 22-10915 (11th Cir. Unpub. Dec.)(September 19, 2022) - 42:07

https://media.ca11.uscourts.gov/opinions/unpub/files/202210915.pdf

Case #14 - USA v. Rosado, No. 21-14065 (11th Cir. Unpub. Dec.)(September 21, 2022) - 45:05

https://media.ca11.uscourts.gov/opinions/unpub/files/202114065.pdf

Episode #11 - Florida Criminal Case Law Update (September 19, 2022 - September 23, 2022) Sep 26, 2022

Show notes

EPISODE: #11: Florida Case Law Update (9/19/22 - 9/23/22)

OVERVIEW - 8 Cases and 1 Rule Amendment

-0 - Florida Supreme Court Cases

4 - First DCA Cases
2 - Second DCA Cases
0 - Third DCA Cases
0 - Fourth DCA Cases
2 - Fifth DCA Case

Case #1 - Brown v. State, No. 1D21-2947 (Fla. 1st DCA)(September 21, 2022) - 1:10

Brown is an Anders Brief case where the 1st DCA found that there were sentencing errors.
http://floridasupremecourt.org/content/download/849723/opinion/212947_NOND_09212022_141645_i.pdf

Case #2 - Gross v. State, No. 1D21-3193 (Fla. 1st DCA)(September 21, 2022) - 4:27

Gross is a violation of probation case out of Escambia County involving changing residence without permission.
https://www.floridasupremecourt.org/content/download/849725/opinion/213193_DC05_09212022_141946_i.pdf

Case #3 - Mizell v. State, No. 1D20-3627 (Fla. 1st DCA)(September 21, 2022) - 5:42

Mizell is a DUI manslaughter case out of Nassau County involving admissibility of the victim’s BAC level.
https://www.floridasupremecourt.org/content/download/849717/opinion/203627_DC05_09212022_140356_i.pdf

Case #4 - Watson v. State, No. 1D22-189 (Fla. 1st DCA)(September 21, 2022) - 9:48

Watson is a 3.850 motion case out of Nassau County involving newly discovered evidence.
https://www.floridasupremecourt.org/content/download/849731/opinion/220189_DC05_09212022_142151_i.pdf

Case #5 - Hay v. State, No.2D21-2167 (Fla. 2d DCA)(September 21, 2022) - 12:14

Hay is a denial of a public defender’s motion to withdraw case out of Lee County.
https://www.floridasupremecourt.org/content/download/849675/opinion/212167_DC03_09212022_083027_i.pdf

Case #6 - State v. Waiters, No. 2D21-1477 (Fla. 2nd DCA)(September 23, 2022) - 13:54

Waiters is a 893.21 Good Samaritan Act case out of Manatee County.
https://www.floridasupremecourt.org/content/download/849844/opinion/211477_DC13_09232022_081840_i.pdf

Case #7 - Goonewardena v. State, No. 5D21-1073 (Fla. 5th DCA)(September 23, 2022) - 18:59

Goonewardena is a competency case out of Seminole County.
https://www.floridasupremecourt.org/content/download/849858/opinion/211073_DC13_09232022_094014_i.pdf

Case #8 - State v. Williamson, No. 5D21-2624 (Fla. 5th DCA)(September 23, 2022) - 22:37

Williamson is a C4 Motion to dismiss case out of Orange County.
https://www.floridasupremecourt.org/content/download/849862/opinion/212624_DC13_09232022_083606_i.pdf

Amendment to Fla. Rule of Crim. Pr. 3.790 - 26:34

https://www.floridasupremecourt.org/content/download/849776/opinion/sc22-103

Episode #10 - Federal Criminal Case Law Update (September 12, 2022 - September 16, 2022) Sep 21, 2022

Show notes

EPISODE :#10: Federal Case Law Update (9/12/22 - 9/16/22)

OVERVIEW

9 cases
0 published decisions
9 unpublished decisions

Case # 1 - USA v. Fisher, No. 21-11879 (11th Cir. Unpub. Dec.)(September 13, 2022) - 1:00

Fisher is a long decision involving Tricare health care fraud involving millions of dollars.
https://media.ca11.uscourts.gov/opinions/unpub/files/202111879.pdf

Case #2 - USA v. Jackson, No. 21-13849 (11th Cir. Unpub. Dec.)(September 13, 2022) - 7:03

Jackson is a compassionate release case where the government moved for summary affirmance.
https://media.ca11.uscourts.gov/opinions/unpub/files/202113849.pdf

Case #3 - USA v. Jeune, No. 21-14420 (11th Cir. Unpub. Dec.)(September 15, 2022) - 8:16

Jeune is a tax fraud case involving the appeal from a resentencing where Ms. Jeune wanted to relitigate issues already litigated in her first appeal.
https://media.ca11.uscourts.gov/opinions/unpub/files/202114420.pdf

Case #4 - USA v. Lundi, No. 20-10898 (11th Cir. Unpub. Dec.)(September 13, 2022) - 10:06

Lundi is a case about motions to withdraw pleas.
https://media.ca11.uscourts.gov/opinions/unpub/files/202010898.pdf

Case #5 - USA v. Moreno, No. 21-14411 (11th Cir. Unpub. Dec.)(September 12, 2022) - 12:44

Moreno is a compassionate release case.
https://media.ca11.uscourts.gov/opinions/unpub/files/202114411.pdf

Case #6 - USA v. Peebles, No. 21-14182 (11th Cir. Unpub. Dec.)(September 12, 2022) - 14:35

Peebles is a §2252A case where Mr. Peebles argues that his sentence under 2252A(b)(2) violates the constitution and that Mr. Pebble’s sexual battery conviction in Virginia is not a predicate offense.
https://media.ca11.uscourts.gov/opinions/unpub/files/202114182.pdf

Case #7 - USA v. Ridling, No. 21-10777 (11th Cir. Unpub. Dec.)(September 13, 2022) - 19:37

Ridling is a guideline intended loss calculation case.
https://media.ca11.uscourts.gov/opinions/unpub/files/202110777.pdf

Case #8 - USA v. Sims, No. 20-12774 (11th Cir. Unpub. Dec.)(September 12, 2022) - 22:47

Sims is a warrantless search of an automobile case.
https://media.ca11.uscourts.gov/opinions/unpub/files/202012774.pdf

Case #9 - USA v. Turner, 19-13704 (11th Cir. Unpub. Dec.)(September 13, 2022) - 31:10

Turner is a warrantless search of the contents of a cell phone case.
https://media.ca11.uscourts.gov/opinions/unpub/files/201913704.pdf

Episode #9 - Florida Criminal Case Law Update (September 12, 2022 - September 16, 2022) Sep 19, 2022

Show notes

EPISODE: #9: Florida Case Law Update (9/12/22 - 9/16/22)

OVERVIEW - 8 Cases

1 - Florida Supreme Court Cases
2 - First DCA Cases
2 - Second DCA Cases
0 - Third DCA Cases
2 - Fourth DCA Cases
1 - Fifth DCA Cases

Case #1 - Mosley v. State, No. SC20-195 (Fla. Sup. Ct.)(September 15, 2022) - 1:00

Mosley is a death case resentencing case out of my own Duval County.
https://www.floridasupremecourt.org/content/download/848980/opinion/sc20-195.pdf

Case #2 - Khayrallah v. State, No. 1D19-2407 (Fla. 1st DCA)(September 14, 2022) - 6:51

Kayrallah is a written threats case again out of my Duval County addressing what it means to send a threat and what a threat is.
https://www.floridasupremecourt.org/content/download/848884/opinion/192407_DC05_09142022_093044_i.pdf

Case #3 - Knapp v. State, No. 1D21-1539 (Fla. 1st DCA)(September 14, 2022) - 10:56

Knapp is a lawfulness of a traffic stop case out of Escambia County.
https://www.floridasupremecourt.org/content/download/848889/opinion/211539_DC05_09142022_094143_i.pdf

Case #4 - Moore v. State, No. 2D22-298 (Fla. 2nd DCA)(September 16, 2022) - 13:27

Moore is an illegal sentence case out of Hillsborough County.
https://www.floridasupremecourt.org/content/download/849110/opinion/220298_DC08_09162022_091433_i.pdf

Case #5 - Tillman v. State, No. 2D21-1269 (Fla. 2nd DCA)(September 16, 2022) - 14:50

Tillman is a sentencing error case involving conflicting oral and written pronouncements of sentence.
https://www.floridasupremecourt.org/content/download/849108/opinion/211269_DC08_09162022_091202_i.pdf

Case #6 - Baker v. State, Nos. 4D20-2112, 2239, 2240 (Fla. 4th DCA)(September 14, 2022) - 16:00

Baker is a 921.0024(2) illegal sentence case out of Martin County.
https://www.floridasupremecourt.org/content/download/848911/opinion/202112_DC13_09142022_095640_i.pdf

Case #7 - Robinson v. State, No. 4D2-1064 (Fla. 4th DCA)(September 14, 2022) - 18:22

Robinson is a driving with suspended license and knowledge of the suspension case out of Broward County.
https://www.floridasupremecourt.org/content/download/848919/opinion/221064_DC05_09142022_100657_i.pdf

Case #8 - Winters v. State, No. 5D22-818 (Fla. 5th DCA)(September 16, 2022) - 20:38

Winters is a 3.850 ineffective assistance of counsel case out of Putnam County.
https://www.floridasupremecourt.org/content/download/849098/opinion/220818_DC08_09162022_092303_i.pdf

Episode #8 - Federal Criminal Case Law Update (September 6, 2022 - September 9, 2022) Sep 14, 2022

Show notes

EPISODE :#8: Federal Criminal Case Law Update (9/6/22 - 9/9/22)

OVERVIEW

7 cases
1 published decisions
6 unpublished decisions

Before we get to last week’s opinions, I wanted to give you this note from the outstanding Federal Public Defenders Conrad Kahn and Jim Skuthan out of Orlando. The important precedential decision in Eugene Jackson was vacated by the 11th Circuit on September 8th and the Court ordered supplemental briefing. In Eugene Jackson, the 11th Circuit recently held that pre-July 2017 Florida cocaine convictions are not “serious drug offenses” under the Armed Career Criminal Act. But apparently the Court wants to revisit the issue.

So, Eugene Jackson is no longer good law, but the issue is also not foreclosed by precedent. So, you can still argue that a pre July 2017 Florida cocaine conviction under 893.13 is not a “serious drug offense” and we will see how the 11th Circuit ultimately rules in the Eugene Jackson decision.

Case # 1 - USA v. Mack and Jaycee Doak, No. 19-15106 (11th Cir. Pub. Dec.)(September 7, 2022)

Mack and Jaycee Doak were convicted of several counts related to Mack Doak’s transporting his three adopted children across state lines to sexually abuse them and Jaycee Doak’s aiding and abetting Mack.

Case #2 - Presendieu v. USA, No. 21-12552 (11th Cir. Unpub. Dec.)(September 9, 2022)

Mr. Presendieu challenges the denial of his 2255 motion that alleged his counsel was ineffective for failing to present evidence of his cooperation at sentencing and for failing to challenge the government’s loss calculation.

Case #3 - USA v. Garcia Vasquez, No. 21-12288 (11th Cir. Unpub. Dec.)(September 9, 2022)

Mr. Garcia Vasquez appeals his 15 month sentence for illegal reentry as substantively unreasonable.

Case #4 - USA v. Hunt, No. 19-14830 (11th Cir. Unpub. Dec.)(September 9, 2022)

Hunt is a First Step Act sentence reduction case where Mr. Hunt was originally sentenced to life or 360 months for various crack cocaine and powder cocaine convictions.

Case #5 - USA v. Mellon, No. 21-12248 (11th Cir. Unpub. Dec.)(September 7, 2022)

Mr. Mellon argues on appeal that the trial court erred by finding the government proved by a preponderance of the evidence that substances found in his residence and vehicle were marijuana and applying the 2K2.1(b)(6)(B) enhancement fro possession of a firearm in connection with another felony and applying the 2K2.1(b)(4) enhancement for possessing a stolen gun because it’s strict liability violates due process.

Case #6 - USA v. Romeu, No. 21-13321 (11th Cir. Unpub. Dec.)(September 9, 2022)

Romeu is a compassionate release case.

Case #7 - USA v. Saldana, No. 20-14707 (11th Cir. Unpub. Dec.)(September 7, 2022)

Saldana is First Step Act sentence reduction case where Mr. Saldana sought a sentence reduction because a jury did not find that he was responsible for 1.5 kilos of crack cocaine and the Apprendi decision requiring a jury finding on the drug amount was decided while his direct appeal was pending.

Episode #7 - Florida Criminal Case Law Update (September 6, 2022- September 9, 2022) Sep 12, 2022

Show notes

EPISODE #7: Florida Criminal Case Law Update (9/6/22 - 9/9/22)

OVERVIEW - 5 Cases

1 - Florida Supreme Court Cases
1 - First DCA Cases
1 - Second DCA Cases
0 - Third DCA Cases
1 - Fourth DCA Cases
1 - Fifth DCA Cases

Florida Evidence Code has been amended to add § 90.2035, which is entitled Judicial Notice of information taken from web mapping services, global satellite imaging sites, or Internet mapping tools. It provides a procedure to have online maps, like google maps, printouts judicially noticed.

Case #1 -Davis v. State, No. SC20-1282 (Fla. Sup. Ct.)(September 8, 2022)

Davis is a case about motions to disqualify a judge and the proper standard of review.

SPOTLIGHT CASE
Case #2 - Bailey v. State, No. 1D21-2023 (Fla. 1st DCA)(September 7, 2022)

Bailey is a case out of Bay County about a violation of probation allegation that was filed after the term of probation expired and whether that time was tolled.

Case #3 - Daniels v. State, No. 2D21-702 (Fla. 2nd DCA)(September 9, 2022)

Daniels is a DUI case out of Sarasota County dealing with reasonable suspicion to conduct a DUI investigation.

Case #4 - Neeley v. State, No. 4D21-3335 (Fla. 4th DCA)(September 7, 2022)

Neeley is a sufficiency of the oath in a 3.850 motion case.

Case #5 - State v. Torres, No. 5D22-21 (Fla. 5th DCA)(September 9, 2022)

Torres is a law enforcement jurisdiction case out of Orange County.

Episode #6 - Federal Criminal Case Law Update (August 29, 2022 - September 2, 2022) Sep 07, 2022

Show notes

EPISODE :#6: Federal Case Law Update (8/29/22 - 9/2/22)
OVERVIEW

9 cases
0 published decisions
9 unpublished decisions

Case # 1 - USA v. Acevedo, No. 21-13357 (11th Cir. Unpub. Dec.)(August 29, 2022)
Acavedo is a substantive reasonableness of the sentence case where Mr. Acavedo challenges his bottom of the guideline sentence based on his lack of criminal history and his co-defendant's lower sentences.

Case #2 - USA v. Alfonso Feliz, 21-13267 (11th Cir. Unpub. Dec.)(Sept. 1, 2022)
Mr. Feliz challenges the trial courts application of 3C1.2 Reckless Endangerment two offense level enhancement and the denial of his request for a 3B1.2 Minor Role reduction.
Case #3 - USA v. Catalano, 21-10759 (11th Cir. Unpub. Dec.)(August 29, 2022)
Ms. Catalano raised on direct appeal an allegation that her trial counsel was ineffective for recommending she plea to a Notice of Maximum Penalties and preserve her right to appeal as opposed to accepting a plea agreement that would have resulted in a lower guideline range, but also with an appeal waiver.

Case #4 - USA v. Devlin, No. 21-12931 (11th Cir. Unpub. Dec.)(August 31, 2022)
Mr. Devlin challenges the criminal forfeiture entered into by the district court several years after the order was entered.

Case #5 - USA v. Eatmon, No. 20-11845 (11th Cir. Unpub. Dec.)(Sept. 1, 2022)
Eatmon is a case sent down from the Supreme Court applying that Court's decision in Concepcion requiring the trial court to consider intervening changes in law when parties raise that issue.

Case #6 - USA v. Lee, No. 20-13968 (11th Cir. Unpub. Dec.)(August 31, 2022)
Mr. Lee challenged the guideline calculation on his case where the case had previously been reduced based on guideline changes to the drug quantity tables.

Case #7 - USA v. Moore, 21-13285 (11th Cir. Unpub. Dec. )(August 29, 2022)
Mr. Moore challenges the trial court's 96 month sentence which was 26 months above the top of the guidelines.

Case #8 - USA v. Saldana, 20-14632 (11th Cir. Unpub. Dec.)(Sept. 1, 2022)
Saldana is a compassionate release case where Mr. Saldana has end stage kidney disease.
Case #9 - USA v. Weaver, No. 21-13137 (11th Cir. Unpub. Dec.)(August 31, 2022)
Weaver is a Fair Sentencing Act sentence reduction case involving the issue of a subsequent request for a sentence reduction when the court has already imposed or reduced the sentence in accordance with the Fair Sentencing Act.

Episode #5 - Florida Criminal Case Law Update (August 29, 2022 - September 2, 2022) Sep 06, 2022

Show notes

EPISODE #5: Florida Case Law Update (8/29/22 - 9/2/22)

OVERVIEW - 5 Cases

2 - Florida Supreme Court Cases
0 - First DCA Cases
1 - Second DCA Cases
2 - Third DCA Cases
0 - Fourth DCA Cases
0 - Fifth DCA Cases

Case #1 -Gordon v. State, No. SC20-284 (Fla. Sup. Ct.)(Sept. 1, 2022)
Mr. Gordon was sentenced to death for First Degree Murder. He argues on appeal that the State impermissibly struck a juror on account of race, that the evidence of premeditation was insufficient, and that his sentence violated the Eighth Amendment.

Case #2 - State v. Mullens, No. SC19-1587 (Fla. Sup. Ct.)(August 31, 2022)
Mr. Mullens was sentenced to death for First Degree Murder. He argued that his trial counsel was ineffective during the penalty phase based on the testimony of two new experts that testified at the post conviction hearing. The Florida Supreme Court reviewed whether the trial court erred by granting a new penalty phase.

Case #3 - Taylor v. State, No. 2D22-1186 (Fla. 2nd DCA)(August 31, 2022)
Mr. Taylor, a juvenile at the time, was sentenced to life with review after 25 years for first degree murder and 30 years (with no judicial review) for attempted robbery. The 2nd DCA determined whether Mr. Taylor was entitled to judicial review on the attempted robbery.

Case #4 - Darling v. State, No. 3D22-0697 (Fla. 3rd DCA)(August 31, 2022)
Darling is a 3.800 Motion to Correct Illegal Sentence case addressing reclassification and minimum mandatory sentences under 775.087.

Case #5 - Ramirez v. State, No. 3D22-1014 (Fla. 3rd DCA)(August 31, 2022)
Ramirez is a 3.800 Motion case where Mr. Ramirez attempted to challenge the validity of his conviction through a 3.800 motion.

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