LEE V. DIXON
v.
STATE OF FLORIDA

Fla. 4th DCA | 2026-02-18
No. 2025-3588
Florida District Court of Appeal, Fourth District (2026)

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Holding

A change of law does not apply retroactively even if established by a controlling Supreme Court decision.


Facts & Procedural History

Lee V. Dixon appealed a state court decision to the Florida District Court of Appeal, Fourth District.…

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Opinion of the Court

PER CURIAM.

Affirmed. Wainwright v. State, 411 So. 3d 392 (Fla. 2025), cert. denied, 145 S.Ct. 2789 (2025) (holding that even if Erlinger v. United States, 602 U.S. 821 (2024), constitutes a change of law, it does not apply retroactively).

KUNTZ, C.J., KLINGENSMITH and SHAW, JJ., concur.


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