RAPHAEL CHARISTIL
v.
STATE OF FLORIDA

Fla. 4th DCA | 2025-08-20
No. 2025-0969
Fein, J., Kuntz, C.J., Levine, J., Conner, J.
2025 FL 7264 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 issued.


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 issued.

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Facts & Procedural History

Raphael Charistil appealed an order denying his rule 3.800 motion in a criminal case from Broward County.…

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Opinion of the Court
Kuntz

DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA

FOURTH DISTRICT

RAPHAEL CHARISTIL, Appellant,

v.

STATE OF FLORIDA, Appellee.

No. 4D2025-0969

[August 20, 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. 09-5699CF10A.

Raphael Charistil, Wewahitchka, pro se.

No appearance required for appellee.

PER CURIAM.

Affirmed. See Wainwright v. State, No. SC2025-0708, 2025 WL 1561151 (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); see also Chapa v. State, 159 So. 3d 362 (Fla. 4th DCA 2015).

KUNTZ, C.J., LEVINE and CONNER, JJ., concur.

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