Morgan v. State
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The Supreme Court approved the decision of the Second District Court of Appeal finding that an order granting Defendant's Fla. R. Crim. P. 3.800(a) motion and determining that Defendant's sentence was illegal was not a final order but remained subject to reconsideration until a final order imposing a corrected sentence was entered, holding that the Second District reached the correct conclusion.
Defendant was convicted of a second-degree murder he committed when he was a juvenile and sentenced to life in prison with the possibility of parole after twenty-five years. In 2016, Defendant filed a Rule 3.800(a) motion asserting that his sentence was an illegal sentence. The trial court granted the motion and ordered a resentencing hearing. By the time the hearing took place in 2018, State v. Michel, 257 So. 3d 3, 4 (Fla. 2018), issued, holding that juvenile offenders' sentences of life with the possibility of parole after twenty-five years do not violate the Eighth Amendment. Consequently, the trial court vacated its prior order granting the Rule 3.800(a) motion and denied the motion. The Second District affirmed. The Supreme Court affirmed, holding that, based on a change in governing law, the trial court properly reconsidered its initial nonfinal order granting Defendant's Rule 3.800(a) motion.
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