Jason L. Williams v. State
235 So. 3d 962
| Fla. Dist. Ct. App. | 2017Background
- Jason L. Williams was convicted of robbery while masked (life with a 30-year minimum mandatory) and two counts of grand theft (10 years each); he was designated both a habitual felony offender (HFO) and a prison releasee reoffender (PRR).
- This Court previously affirmed Williams’s conviction and sentence on direct appeal.
- Williams filed a Rule 3.800(a) motion challenging his HFO and PRR designations; the trial court dismissed that first motion as facially insufficient (not on the merits) and this Court affirmed that dismissal.
- Williams then filed a second Rule 3.800(a) motion raising the same HFO and PRR challenges but attaching supporting record materials to cure the prior facial deficiency.
- The trial court denied the second motion as an improper successive motion; Williams appealed the denial.
- The Fifth District affirmed the denial as to the HFO designation but reversed and remanded for the trial court to reach the merits of the PRR claim, finding the second motion was not barred because the first was not decided on the merits.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Legality of PRR designation (dates used to determine 3-year window) | Williams: PRR designation is illegal because the court used incorrect dates; record attachments show error | State: The motion is successive and barred | Court: First motion was dismissed as facially insufficient (not on merits); second motion is facially sufficient and not barred — remand for merits on PRR claim |
| Successive Rule 3.800(a) motion doctrine | Williams: Second motion relates back and corrects prior deficiency; therefore permissible | State: Successive motions re-litigating same issue are barred by collateral estoppel/law of the case | Court: Successive motions are allowed generally, but re-litigation of an issue previously decided on the merits is barred; because prior motion lacked merits adjudication, this second motion is allowed as to PRR |
| Legality of HFO designation | Williams: HFO designation improper (same challenge) | State: HFO designation stands; procedural bar applies | Court: Affirmed denial as to HFO designation (no further discussion) |
Key Cases Cited
- Johnson v. State, 60 So. 3d 1045 (Fla. 2011) (error correctable on rule 3.800(a) must be apparent from the face of the record)
- Smith v. State, 143 So. 3d 1023 (Fla. 4th DCA 2014) (standard of review for rule 3.800(a) legal issues is de novo)
- McBride v. State, 848 So. 2d 287 (Fla. 2003) (successive, repetitive rule 3.800 motions are barred under collateral estoppel principles)
- Ellis v. State, 853 So. 2d 484 (Fla. 5th DCA 2003) (successive rule 3.800(a) motions that re-litigate issues violate the law of the case doctrine)