FERRIS VAUGHNER
v.
STATE OF FLORIDA

Fla. 4th DCA | 2026-03-04
No. 2025-3860
Bober, J., Levine, J., Conner, J., Shepherd, J.
2026 FL 2412 Florida District Court of Appeal, Fourth District (2026)

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Holding

A change in law established by Erlinger v. United States does not apply retroactively to cases on collateral review.


Headnotes

[1] A change in law established by a United States Supreme Court decision does not apply retroactively to cases on collateral review absent a determination that retroactive a…

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Facts & Procedural History

Ferris Vaughner appealed the denial of his Rule 3.800 motion in a criminal case from Broward County Circuit Court.…

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Opinion of the Court

DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA FOURTH DISTRICT

FERRIS VAUGHNER, Appellant,

v.

STATE OF FLORIDA, Appellee.

No. 4D2025-3860

[March 4, 2026]

Appeal of order denying rule 3.800 motion from the Circuit Court for the Seventeenth Judicial Circuit, Broward County; Bernard I. Bober, Judge; L.T. Case No. 062018CF000190A88810.

Ferris Vaughner, Milton, pro se.

No appearance required for appellee.

PER CURIAM.

Affirmed. See Maye v. State, 368 So. 3d 531 (Fla. 6th DCA 2023), review granted, No. SC2023-1184, 2024 WL 1796831 (Fla. Apr. 25, 2024); Wainwright v. State, 411 So. 3d 392 (Fla. 2025) (holding that even if Erlinger v. United States, 602 U.S. 821 (2024) constitutes a change of law, it does not apply retroactively).

LEVINE, CONNER and SHEPHERD, JJ., concur.

* * *

Not final until disposition of timely-filed motion for rehearing.


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