Williams v. State
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The Supreme Court approved the First District Court of Appeal’s decision ruling that the Dangerous Sexual Felony Offender Act (the DSFO Act) authorizes a mandatory minimum life sentence regardless of the statutory maximum for the crimes.
The First District certified conflict with Wilkerson v. State, 143 So. 3d 462 (Fla. 5th DCA 2014), in which the First District Court of Appeal concluded that, when the statutory maximum for a particular crimes is less than twenty-five years, the DSFO authorizes a trial court to impose only a mandatory minimum term of twenty-five years’ imprisonment. In the instant case, the trial court sentenced Defendant under the DSFO Act to a mandatory minimum life sentence for a second-degree felony that generally carried a fifteen-year statutory maximum. The Supreme Court approved the First District’s decision in Williams and disapproved the Fifth District’s decision in Wilkerson to the extent it was inconsistent with this opinion, holding that, in upholding the sentence int his case, the First District interpreted the “25 to life” provision in the DSFO Act consistently with Mendenhall v. State, 48 So, 3d 740 (Fla. 2010), which controls this case.
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