Juan F. Perez v. State of Florida
5D2024-2599
Fla. Dist. Ct. App.Mar 21, 2025Background
- Juan F. Perez was convicted in 2015 of aggravated battery with a firearm, a second-degree felony under Florida law.
- The jury found Perez discharged a firearm and caused great bodily harm, triggering the 10-20-Life mandatory minimum sentencing statute.
- Based on these findings, Perez was sentenced to 35 years in prison, with a 25-year mandatory minimum.
- Perez filed a postconviction motion under Fla. R. Crim. P. 3.800(a), arguing that his sentence was illegal because it exceeded the authorized statutory maximum for his offense.
- The trial court denied his motion, finding the sentence lawful; the State, however, later agreed with Perez’s position on appeal.
Issues
| Issue | Perez's Argument | State's Argument | Held |
|---|---|---|---|
| Legality of Sentence Exceeding Max | Sentence over 15-year max (plus 25-year min) not authorized by statute | Agreed; no authority for >25-year mandatory minimum | Sentence above 25-year mandatory minimum is illegal |
| Application of 10-20-Life Statute | Court could only impose 25-to-life mandatory min; could not add extra years | Agreed; must follow statutory framework | Mandatory min 25 years to life is permissible, not more |
Key Cases Cited
- Hatten v. State, 203 So. 3d 142 (Fla. 2016) (statutory maximum cannot be exceeded absent further authority, even with mandatory minimums under 10-20-Life)
- Mendenhall v. State, 48 So. 3d 740 (Fla. 2010) (explains 10-20-Life statute’s framework for mandatory minimum sentences)
- Wynn v. State, 277 So. 3d 281 (Fla. 5th DCA 2019) (construes 10-20-Life statute and limits on combined sentences)
- Wooden v. State, 42 So. 3d 837 (Fla. 5th DCA 2010) (limits on sentencing when mandatory minimums apply)