Mathis v. State of Florida, 2D2023-1764

Clyde Mathis was convicted of home invasion robbery, burglary, and witness tampering in Florida and sentenced to lengthy terms as a habitual felony offender (HFO) and prison releasee reoffender (PRR).
The sentences included two life terms and a 30-year sentence, all to run concurrently, based on prior convictions.
Mathis challenged his sentences on appeal, specifically arguing that the State failed to provide evidence to support the enhanced HFO/PRR status.
Mathis filed a motion under Florida Rule of Criminal Procedure 3.800(b) to correct alleged sentencing errors during the appeal.
The trial court denied the motion, finding the sentencing packet was part of the record and supported the status enhancements.
On review, the appellate court found the sentencing packet was never admitted into evidence, making it insufficient to support the enhancements, and remanded for resentencing.

Issue	Mathis's Argument	State's Argument	Held
Sufficiency of evidence for HFO/PRR enhancements	State failed to introduce proof of prior convictions in evidence	Sentencing packet was filed and reviewed by the court, counsel acknowledged prior record	Sentencing packet was not admitted as evidence; enhancements not properly supported
Opportunity for State to provide evidence on remand	Mathis should not be classified as HFO/PRR without evidentiary basis	No objection from defense at sentencing, so State should have opportunity on remand	State may present evidence on remand to support enhancements

Mitchell v. State, 780 So. 2d 282 (Fla. 4th DCA 2001) (outlines evidentiary requirements for HFO/PRR sentencing)
Sanders v. State, 765 So. 2d 161 (Fla. 2d DCA 2000) (sets forth procedure for State proving eligibility for enhanced sentencing)
Bellamy v. State, 712 So. 2d 409 (Fla. 2d DCA 1998) (permits State to offer proof on remand where no contemporaneous objection was made)