198 So. 3d 1084
Fla. Dist. Ct. App.2016Background
- In 1990 Anthony Williams, then 17, was convicted of first-degree felony murder and sentenced to life imprisonment under the 1988 statute that permitted life with parole eligibility after a 25-year mandatory minimum.
- Williams challenged his sentence in 2015 via a pro se motion for postconviction relief, arguing Miller v. Alabama made his life sentence unconstitutional and seeking resentencing under chapter 2014-220, Laws of Florida.
- The trial court denied Miller-based relief but ordered the sentencing form amended to reflect the 25-year mandatory minimum for parole eligibility under the 1993 form.
- While the appeal was pending, the Florida Supreme Court held in a separate case that Miller can apply to pre-1994 life-with-parole sentences when the practical effect is the same as life without parole, requiring resentencing under Horsley and chapter 2014-220.
- The record in Williams’s case lacked any information about his presumptive parole release date (PPRD) or the Commission’s review recommendation, making it unclear whether his PPRD effectively denies any realistic chance of release.
- The Fifth District reversed and remanded for the trial court to determine Williams’s PPRD and Commission review recommendation to decide whether resentencing under Horsley and chapter 2014-220 is required.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Miller v. Alabama renders Williams’s life sentence under the pre-1994 statute unconstitutional | Williams: Miller requires individualized juvenile sentencing review and entitles him to resentencing under chapter 2014-220 because his sentence is effectively life without parole | State: Miller does not apply because Williams was sentenced under a statute that provided parole eligibility after 25 years | Court: Remanded for factual determination of PPRD/Commission review; if PPRD makes release virtually impossible, resentencing under Horsley/ch.2014-220 is required |
Key Cases Cited
- Miller v. Alabama, 132 S. Ct. 2455 (2012) (mandatory life-without-parole for juveniles violates Eighth Amendment; requires individualized sentencing)
- Graham v. Florida, 560 U.S. 48 (2010) (juvenile life without parole unconstitutional for nonhomicide offenses; limits on sentencing juveniles)
- Horsley v. State, 160 So. 3d 393 (Fla. 2015) (Florida remedy for Miller is resentencing under chapter 2014-220)
- Williams v. State, 578 So. 2d 1116 (Fla. 5th DCA 1991) (affirming Williams’s conviction)