Detarsha Castro Bradley v. State of Florida
223 So. 3d 421
| Fla. Dist. Ct. App. | 2017Background
- Appellant Castro was sentenced to consecutive mandatory minimum terms under Florida’s 10‑20‑Life statute for aggravated assault and possession of a firearm by a convicted felon.
- This court previously affirmed those consecutive mandatory minimums based on its en banc decision in Walton v. State (1st DCA).
- The Florida Supreme Court later quashed and remanded for reconsideration in light of its decisions in Walton (Fla. 2016) and Williams v. State.
- Williams held that consecutive mandatory minimums are impermissible when multiple firearm offenses arise from the same criminal episode and the firearm was possessed but not discharged; consecutive sentences may be permissible (but not mandatory) if multiple victims are shot at contemporaneously.
- Lower‑court 1st DCA decisions (including Burns) read Williams to permit, but not require, consecutive mandatory minimums where multiple firearm offenses arose in a single episode and only one victim was shot.
- The court vacated Castro’s sentence because the trial judge believed consecutive mandatory minimums were required by prior precedent, and remanded for the trial court to exercise discretion to impose concurrent or consecutive mandatory minimums.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether mandatory minimum firearm sentences under 10‑20‑Life must be imposed consecutively when multiple firearm offenses arise from the same criminal episode and the firearm was discharged at a single victim | Castro: Consecutive mandatory minimums are not required where offenses arise from the same episode and only one victim was shot; sentencing discretion should apply | State: Under prior precedent, consecutive mandatory minimums must be imposed for multiple firearm offenses | Court vacated sentence and remanded for the trial court to decide whether to impose concurrent or consecutive mandatory minimums (discretionary, not mandatory) |
Key Cases Cited
- Walton v. State, 106 So. 3d 522 (Fla. 1st DCA 2013) (1st DCA en banc decision supporting mandatory consecutive minimums under earlier precedent)
- Williams v. State, 186 So. 3d 989 (Fla. 2016) (Florida Supreme Court: consecutive mandatory minimums impermissible when offenses arise from same episode and firearm merely possessed; consecutive permissible but not mandatory if multiple victims are shot at)
- Walton v. State, 208 So. 3d 60 (Fla. 2016) (Florida Supreme Court decision clarifying Walton and related sentencing principles)
- Burns v. State, 212 So. 3d 546 (Fla. 1st DCA 2017) (1st DCA read Williams to permit discretionary consecutive sentences where a single victim was shot during one episode)
- Torres‑Rios v. State, 205 So. 3d 883 (Fla. 5th DCA 2016) (holds that concurrent sentences must be imposed where a single shot is fired at one person during a single criminal episode; conflict certified)