JUSTIN PANTZER
v.
STATE OF FLORIDA

Fla. 4th DCA | 2026-04-29
No. 2025-3356
Roby, J., Kuntz, C.J., Forst, J., Shepherd, J.
2026 FL 4988 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 already final on direct appeal.


Headnotes

[1] A change in law established by federal court decision does not apply retroactively to criminal convictions that were final on direct appeal.

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Facts & Procedural History

Justin Pantzer, proceeding pro se, appealed an order denying his rule 3.800 motion in a criminal case from Martin County Circuit Court.…

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Opinion of the Court

DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA

FOURTH DISTRICT

JUSTIN PANTZER, Appellant,

v.

STATE OF FLORIDA, Appellee.

No. 4D2025-3356

[April 29, 2026]

Appeal of order denying rule 3.800 motion from the Circuit Court for the Nineteenth Judicial Circuit, Martin County; William L. Roby, Judge; L.T. Case No. 432007CF001105CFAXMX.

Justin Pantzer, Lake City, pro se.

No appearance required for appellee.

PER CURIAM.

Affirmed. See Wainwright v. State, 411 So. 3d 392 (Fla. 2025), cert. denied, U.S. , 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); see also Maye v. State, 368 So. 3d 531, 532 (Fla. 6th DCA 2023), rev. granted, No. SC2023-1184, 2024 WL 1796831 (Fla. Apr. 25, 2024).

KUNTZ, C.J., FORST and SHEPHERD, JJ., concur.

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