JAMES T. INGRAM, *W*
v.
STATE OF FLORIDA

Fla. 4th DCA | 2025-07-02
No. 2025-0929
Fein, J., Warner, J., Levine, J., Klingensmith, J.
2025 FL 5590 Florida District Court of Appeal, Fourth District (2025)

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Holding

A change in law established by Erlinger v. United States does not apply retroactively to cases that were final when the decision was rendered.


Headnotes

[1] A change in law established by a United States Supreme Court decision does not apply retroactively to criminal cases that became final before the decision was rendered.

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Facts & Procedural History

James T. Ingram appealed the denial of his Rule 3.800 motion in a criminal case from Broward County. The underlying conviction became final in 2003.…

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Opinion of the Court
Klingensmith

DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA

FOURTH DISTRICT

JAMES T. INGRAM, Appellant,

v.

STATE OF FLORIDA, Appellee.

No. 4D2025-0929

[July 2, 2025]

Appeal of order denying rule 3.800 motion from the Circuit Court for the Seventeenth Judicial Circuit, Broward County; Martin S. Fein, Judge; L.T. Case No. 03-019684-CF10A.

David M. Lamos of the Law Offices of David M. Lamos, Fort Pierce, for appellant.

No appearance required for appellee.

PER CURIAM.

Affirmed. See Wainwright v. State, No. SC2025-0708, --- So. 3d ---, 2025 WL 1561151, *5-*6 (Fla. June 3, 2025) (holding that, even if Erlinger v. United States, 602 U.S. 821 (2024), constitutes a change in law, it does not apply retroactively to cases that were final when it was decided).

WARNER, LEVINE and KLINGENSMITH, JJ., concur.

* * *


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