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State v. Adkins
71 So. 3d 184
Fla. Dist. Ct. App.
2011
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Background

  • The State appeals an order dismissing motions by 42 defendants in 46 criminal proceedings in Manatee County.
  • The circuit court held Florida Statute 898.13 unconstitutional as applied.
  • Circuit court relied primarily on Shelton v. Secretary, Department of Corrections (M.D. Fla. 2011) and related Florida decisions (Washington, Anderson, Barnett).
  • The order at issue was certified by the district court under Florida Rule of Appellate Procedure 9.125 for immediate Supreme Court review due to public importance.
  • The decision could affect numerous drug prosecutions statewide and potentially inmate releases if the ruling is upheld.
  • The court noted potential interdistrict conflicts and urged uniform statewide resolution.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Constitutionality of 898.13 State contends 898.13 is unconstitutional as applied. Circuit court aligned with Shelton/Washington and others opposing 898.13. Certification granted; constitutionality not resolved here.
Need for immediate resolution State argues immediate resolution is warranted due to public importance. Delay would hinder administration of justice; expedited review appropriate. Order certified for immediate Supreme Court review.
statewide impact and uniformity Resolution will affect prosecutions across Florida and ensure uniform interpretation. Current circuit-level split risks conflicting applications nationwide until resolved. Court certifies due to great public importance and statewide impact.

Key Cases Cited

  • Pardo v. State, 596 So.2d 665 (Fla.1992) (interdistrict decisions bind trial courts when no interdistrict conflict)
  • Chapman v. Pinellas Cnty., 423 So.2d 578 (Fla.2d DCA 1982) (same-binding effect for district court decisions absent interdistrict conflict)
  • Heggs v. State, 718 So.2d 263 (Fla.2d DCA 1998) (illustrates exceptional appeals and rule 9.125 usage)
  • Morel, In re Commitment of, 67 So.3d 1062 (Fla.2d DCA 2010) (illustrative of exceptional appeals under rule 9.125)
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Case Details

Case Name: State v. Adkins
Court Name: District Court of Appeal of Florida
Date Published: Sep 28, 2011
Citation: 71 So. 3d 184
Docket Number: No. 2D11-4559
Court Abbreviation: Fla. Dist. Ct. App.