Casiano v. State
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The Supreme Court held that a defendant's potential designation as a prison releasee reoffender (PRR) under Fla. Stat. 775.082(9)(a)1. is not a sufficient collateral legal consequence to preclude dismissal of an appeal challenging a state prison sentence erroneously imposed pursuant to a trial court's dangerousness finding under section 775.082(1).
The decision of the Fourth District Court of Appeal in this case expressly and directly conflicted with that of the First District Court of Appeal in Johnson v. State, 260 So. 3d 502 (Fla. 1st DCA 2018). The district courts reached separate conclusions as to whether a defendant's potential designation as a prison releasee reoffender is a sufficient collateral legal consequence precluding dismissal of such an appeal. The Supreme Court approved the Fourth District's decision and disapproved the First District's decision, holding that a defendant's potential PRR designation under section 775.082(9)(a)1. is not a sufficient collateral legal consequence flowing from a state prison sentence erroneously imposed pursuant to a trial court's dangerousness finding to preclude dismissal of an appeal as moot where the defendant has served the incarcerate portion of the sentence.
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