State of Florida v. Ray Mon Wright
180 So. 3d 1043
| Fla. Dist. Ct. App. | 2015Background
- Ray Mon Wright committed aggravated assault and burglary on November 6, 2013; convictions affirmed on appeal.
- State sought enhanced sentencing under the Prison Releasee Reoffender (PRR) statute based on Wright’s June 13, 2013 release after a June 12, 2013 judgment committing him to DOC custody for an accessory-after-the-fact sentence (454 days with 454 days’ credit).
- Wright physically walked out of Duval County Jail because his sentence was treated as time served; DOC records listed his Release Facility as “Central Office.”
- Trial court declined to impose PRR enhancement, reasoning Wright was released from county jail (not a DOC-operated state correctional facility).
- The district court affirmed convictions but reversed and remanded for resentencing, holding Wright’s release constituted a constructive release from DOC custody making him a PRR.
Issues
| Issue | State's Argument | Wright's Argument | Held |
|---|---|---|---|
| Whether "released from a state correctional facility operated by the Department of Corrections" requires physical release from a DOC facility | Constructive release counts: when defendant was committed to DOC and released within three years, PRR applies even if physically released from county jail | Physical release from a DOC-operated facility is required; release from county jail does not trigger PRR | PRR applies: Wright’s release was a constructive release from DOC custody; trial court erred by not imposing PRR enhancement |
| Whether caselaw and statutory interpretation support applying PRR to releases that occur while physically in county jail | Reliance on Louzon and Taylor: courts should avoid a form-over-substance result and treat legal/DOC custody expiration as release from DOC | Reliance on literal text and strict construction; applying PRR here would rewrite statute and should be left to Legislature | Majority adopts Louzon/Taylor reasoning; concurrence agrees without invoking absurdity doctrine; dissent would deny certification and adhere to literal text |
Key Cases Cited
- Reeves v. State, 957 So.2d 625 (Fla. 2007) (standard of review for statutory interpretation and de novo review)
- Louzon v. State, 78 So.3d 678 (Fla. 5th DCA 2012) (construed PRR to include constructive release from DOC custody)
- Taylor v. State, 114 So.3d 366 (Fla. 4th DCA 2013) (adopted Louzon; held release from federal custody while housed in county jail qualified as constructive release)
- Cassista v. State, 57 So.3d 265 (Fla. 5th DCA 2011) (distinguished: temporary detention differs from a sentence that expires while in county jail)
- State v. Hackley, 95 So.3d 92 (Fla. 2012) (limits on absurdity doctrine; doctrine to be used rarely)
- Thompson v. State, 695 So.2d 691 (Fla. 1997) (criminal statutes construed in favor of the accused)
- W. Fla. Reg’l Med. Ctr., Inc. v. See, 79 So.3d 1 (Fla. 2012) (text and plain-meaning rules govern statutory construction)