Wiley v. State
125 So. 3d 235
| Fla. Dist. Ct. App. | 2013Background
- Eric Wiley, a habitual felony offender, was charged with five counts including second- and third-degree murder and firearm offenses.
- At trial he was convicted on all counts; the court initially sentenced him to life for second-degree murder under 10/20/Life.
- On appeal, this court vacated the second-degree murder conviction and remanded for resentencing on the third-degree murder conviction.
- At remand, the State sought a life sentence under 10/20/Life; defense argued the discharge was accidental and that 10/20/Life should not apply.
- The trial court ruled that the 10/20/Life statute applied and, combined with habitual offender status, imposed life with a 25-year mandatory minimum.
- Wiley challenges the 10/20/Life application, the constitutional validity of the sentence, and the manner of imposition for count II.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does 10/20/Life apply to an accidental discharge? | Wiley contends the statute targets intentional discharge, not accidents. | Wiley argues the statute should not apply when there is no intent to shoot. | The statute applies when discharge occurs during a qualifying felony, regardless of intent. |
| Is life imprisonment under 10/20/Life unconstitutional as applied here? | Wiley asserts the length violates Eighth/Florida constitutional limits given the circumstances. | State contends no constitutional violation given crime's gravity and legislative deference. | No constitutional violation; sentence not grossly disproportionate. |
| Was the combination of reclassification and mandatory minimum properly applied to count II? | Wiley argues the 10/20/Life minimum cannot be added to a life sentence beyond 30 years max. | Court may reclassify to a higher degree and impose a 25-year minimum with life maximum under law. | Yes; reclassification and mandatory minimum were properly imposed and authorized by law. |
| May the court impose a longer sentence than the mandatory minimum under 10/20/Life when authorized by law? | Not applicable beyond the mandatory minimum. | Section 775.087(2)(b) allows longer sentences where authorized by law. | Court may exceed the minimum when authorized; here, habitual offender status permits life after reclassification. |
Key Cases Cited
- Mendenhall v. State, 48 So.3d 740 (Fla. 2010) (permits discretionary 25-to-life minimum under 10/20/Life despite statutory max)
- McDonald v. State, 957 So.2d 605 (Fla.2007) (policy of deterring firearm use; statutory interpretation of 10/20/Life)
- Nelson v. State, 811 So.2d 761 (Fla. 4th DCA 2002) (upholds 25-year minimum for discharging a firearm during crime)
- Andrews v. State, 82 So.3d 979 (Fla.1st DCA 2011) (proportionality and review standards for length of sentence)
- Hall v. State, 823 So.2d 757 (Fla.2002) (Eight Amendment limits on punishment focus on method, not duration)
- Lightbourne v. McCollum, 969 So.2d 326 (Fla.2007) (discusses proportionality and sentencing standards)
- Gregg v. Georgia, 428 U.S. 153 (U.S. Supreme Court 1976) (capital punishment framework influencing proportionality analysis)
- Adaway v. State, 902 So.2d 746 (Fla.2005) (proportionality review for long prison terms)
- Walker v. State, 473 So.2d 694 (Fla.1st DCA 1985) (authorizes life sentence for certain felony classifications when reclassified)
- Solem v. Helm, 463 U.S. 277 (U.S. Supreme Court 1983) (three-factor framework for gross disproportionality)