WILLIE ROBINSON
v.
STATE OF FLORIDA

Fla. 3d DCA | 2025-09-24
No. 2025-1378
Scales, C.J., Lobree, J., Gooden, J., Jean, J.
2025 FL 8183 Florida District Court of Appeal, Third 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 does not apply retroactively to cases that were final when the change was decided.

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Facts & Procedural History

Willie Robinson appealed a decision from the Circuit Court for Miami-Dade County. The appeal involved the retroactive application of a recent legal ch…

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Opinion of the Court
Scales

Third District Court of Appeal State of Florida

Opinion filed September 24, 2025. Not final until disposition of timely filed motion for rehearing.

________________

No. 3D25-1378 Lower Tribunal No. F07-8599 ________________

Willie Robinson, Appellant,

vs.

The State of Florida, Appellee.

An Appeal under Florida Rule of Appellate Procedure 9.141(b)(2) from the Circuit Court for Miami-Dade County, Lody Jean, Judge.

Willie Robinson, in proper person.

James Uthmeier, Attorney General, for appellee.

Before SCALES, C.J., and LOBREE and GOODEN, JJ.

PER CURIAM.

Affirmed. See Wainwright v. State, 411 So. 3d 392, 399 (Fla. 2025)

Footnotes
2 (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); Arias v. State, 413 So. 3d 999 (Fla. 3d DCA 2025).

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