Ronald Williams v. State of Florida
186 So. 3d 989
| Fla. | 2016Background
- On Feb. 12, 2008 Ronald Williams fired a gun into the air after an altercation; four victims led to four aggravated-assault-with-firearm counts.
- Jury convicted Williams on all four counts; each conviction triggered a 20-year mandatory minimum under Fla. Stat. §775.087(2)(a) (the "10-20-Life" law).
- At sentencing the State argued §775.087(2)(d) requires mandatory minimums to run consecutively; Williams argued the court retained discretion to run them concurrently for offenses arising from one criminal episode.
- Trial judge imposed four consecutive 20-year minimums (80 years); the Fourth DCA affirmed and certified the question of great public importance.
- The Florida Supreme Court granted review to resolve whether §775.087(2)(d) compels consecutive mandatory minimums when offenses arise from a single criminal episode.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether §775.087(2)(d) requires consecutive mandatory minimums when multiple qualifying offenses arise from one criminal episode | Williams: Court has discretion to order concurrent or consecutive sentences for offenses from single episode; Christian permits concurrency absent multiple injuries/multiple victims | State: Plain language of §775.087(2)(d) and the word “shall” mandate consecutive minimums for each qualifying count | No — §775.087(2)(d) does not require consecutive sentences for qualifying offenses arising from the same episode; consecutive imprisonment is permissible but not mandatory |
Key Cases Cited
- State v. Christian, 692 So.2d 889 (Fla. 1997) (permits consecutive mandatory minimums where defendant shoots at/injures multiple victims; concurrency where firearm only possessed)
- State v. Sousa, 903 So.2d 923 (Fla. 2005) (interpreting §775.087(2)(d) and reaffirming trial court discretion to impose consecutive mandatory minimums in appropriate cases)
- Palmer v. State, 438 So.2d 1 (Fla. 1983) (Legislature did not intend consecutive mandatory minimums for multiple victims during a single criminal episode when firearm merely possessed)
- State v. Thomas, 487 So.2d 1043 (Fla. 1986) (upholds consecutive minimums where separate injuries/victims shown)
- Bennett v. St. Vincent’s Med. Ctr., Inc., 71 So.3d 828 (Fla. 2011) (statutory interpretation principle: give plain language full effect and avoid readings that render provisions meaningless)