Williams v. State
197 So. 3d 569
| Fla. Dist. Ct. App. | 2016Background
- Curtis Williams (juvenile at offense, 17) was convicted of armed kidnapping of a child under 13 (life felony) plus attempted robbery and aggravated assault; sentenced at 19 to 50 years with a 20-year minimum mandatory on the kidnapping count, concurrent 20-year terms on others, with 417 days jail credit.
- Williams filed a third Florida Rule of Criminal Procedure 3.850 motion arguing his 50-year-with-20-year-minimum sentence is a de facto life term that violates Graham v. Florida as interpreted by the Florida Supreme Court in Henry and Gridine.
- He sought resentencing under the 2014 statutory provisions (sections 775.082, 921.1401, 921.1402) permitting review after 20 years for juvenile nonhomicide offenders.
- The postconviction court deemed the motion untimely under rule 3.850 but reached the merits under rule 3.800(a) and found the sentence was not a de facto life sentence.
- The Second District reviewed the legal issue de novo and analyzed retroactivity; it concluded Graham and Henry apply retroactively but held Williams’s sentence did not violate Graham because he would be released during his natural life (even if he served all 50 years) and is eligible for gain-time under statutes.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a 50-year sentence with a 20-year minimum-mandatory for a juvenile nonhomicide offender is a de facto life term in violation of Graham/Henry | Williams: the aggregate sentence functions as de facto life imprisonment without a meaningful opportunity for release; entitles him to resentencing under Henry/Gridine | State: even if served in full, Williams would be released at ~age 68 and is eligible for gain-time; sentence is not the functional equivalent of life without parole | Court: Sentence is not a de facto life term; denial of postconviction relief affirmed |
| Retroactivity and timeliness of Graham/Henry-based claims under rule 3.850 | Williams: Graham/Henry should apply to his final sentence and permit relief | State: procedural timeliness may bar relief | Court: Graham and Henry principles apply retroactively; timeliness issues exist but court reached the merits and denied relief on substantive grounds |
Key Cases Cited
- Graham v. Florida, 560 U.S. 48 (2010) (categorical rule barring life without parole for juvenile nonhomicide offenders)
- Miller v. Alabama, 132 S. Ct. 2455 (2012) (mandatory life sentences for juveniles unconstitutional; retroactivity discussion cited)
- Henry v. State, 175 So. 3d 675 (Fla. 2015) (Florida Supreme Court applying Graham to lengthy terms of years that function as de facto life sentences)
- Gridine v. State, 175 So. 3d 672 (Fla. 2015) (companion Florida Supreme Court decision addressing Graham's application to term-of-years sentences)
- Falcon v. State, 162 So. 3d 954 (Fla. 2015) (held Miller applies retroactively and provided timing guidance for 3.850 filings)