Alonso v. State of Florida, 2D2023-2304

Jesse Alonso was convicted of resisting arrest with violence in Pasco County, Florida.
He appealed his conviction and sentence, arguing that the trial court erred in admitting certain evidence at trial.
Alonso also challenged his sentence enhancements as a prison releasee reoffender and habitual felony offender.
The court reviewed the evidentiary rulings and the sentencing enhancements for error.
The appellate court evaluated whether any error in the sentencing process was harmless based on the evidence presented.

Issue	Alonso's Argument	State's Argument	Held
Admission of Evidence	Trial court erred by admitting specific evidence at trial	Admission was proper and not an abuse of discretion	No abuse of discretion; conviction affirmed
Sentence Enhancements (Prison Releasee Reoffender & Habitual Felony Offender)	Trial court erred in finding statutory requirements met; challenges based on recent precedent	Any error is harmless since record shows Alonso qualifies for enhancements	Any error deemed harmless; sentence affirmed
Fundamental Error Analysis	Presented evidentiary argument as fundamental error	Argued error, if any, was preserved and not fundamental	No fundamental error analysis needed; issue preserved correctly
Need for Contemporaneous Objection After Motion in Limine	Objection should be preserved for appellate review	Motion in limine sufficient to preserve error for appeal	Motion in limine preserves issue; no need to renew objection

Galindez v. State, 955 So. 2d 517 (Fla. 2007) (holding harmless error analysis applies to sentencing enhancement errors under Apprendi and its progeny)
Dessaure v. State, 891 So. 2d 455 (Fla. 2004) (establishing abuse of discretion standard for review of evidentiary rulings)
Cash v. State, 875 So. 2d 829 (Fla. 2d DCA 2004) (clarifying that a party is not required to renew an objection made in a motion in limine at trial)