CANDY SUE LOVALL
v.
STATE OF FLORIDA

Fla. 5th DCA | 2025-07-15
No. 2025-0540
Naberhaus, J., Jay, C.J., Makar, J., Boatwright, J.
2025 FL 5914 Florida District Court of Appeal, Fifth District (2025)

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Holding

A life sentence does not violate article 1, section 17 of the Florida Constitution, which forbids an indefinite term of imprisonment.


Headnotes

[1] A life sentence imposed by a trial court does not constitute an indefinite term of imprisonment in violation of article 1, section 17 of the Florida Constitution.

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Key Quotes

“a life sentence does not violate article 1, section 17 of the Florida Constitution, which forbids an indefinite term of imprisonment”

Court's holding citing Ratliff v. State, 914 So. 2d 938, 940 (Fla. 2005)

Facts & Procedural History

Candy Sue Lovall appealed from a judgment in the Circuit Court for Brevard County. The appeal involved a challenge to a life sentence on constitutiona…

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Opinion of the Court
Jay

FIFTH DISTRICT COURT OF APPEAL

STATE OF FLORIDA

_____________________________

Case No. 5D2025-0540 LT Case No. 05-1998-CF-16951-A _____________________________

CANDY SUE LOVALL,

Appellant,

v.

STATE OF FLORIDA,

Appellee. _____________________________ 3.800 Appeal from the Circuit Court for Brevard County. Michelle Lynn Naberhaus, Judge. Candy Sue Lovall, Florida City, pro se. James Uthmeier, Attorney General, Tallahassee, and Roberts J. Bradford, Jr., Assistant Attorney General, Daytona Beach, for Appellee.

July 15, 2025

PER CURIAM. AFFIRMED. See Ratliff v. State, 914 So. 2d 938, 940 (Fla. 2005) (holding that a life sentence does not violate article 1, section 17 of the Florida Constitution, which forbids an indefinite term of imprisonment). 2 JAY, C.J., and MAKAR and BOATWRIGHT, JJ., concur.

_____________________________

Not final until disposition of any timely and authorized motion under Fla. R. App. P. 9.330 or 9.331. _____________________________


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