LAWRENCE FLOOD, JR.
v.
STATE OF FLORIDA

Fla. 4th DCA | 2025-09-17
No. 2025-2108
Roby, J., May, J., Gerber, J., Klingensmith, J.
2025 FL 8035 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 already final on direct appeal.


Headnotes

[1] A change in law established by subsequent appellate decision does not apply retroactively to cases that were final on direct appeal prior to the change.

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Facts & Procedural History

Lawrence D. Flood, Jr. filed a rule 3.800 motion in the Circuit Court for Martin County seeking relief from his conviction. The trial court denied the…

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Opinion of the Court
Klingensmith

DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA

FOURTH DISTRICT

LAWRENCE D. FLOOD, JR., Appellant,

v.

STATE OF FLORIDA, Appellee.

No. 4D2025-2108

[September 17, 2025]

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. 432013CF000634A.

Lawrence D. Flood, Jr., Okeechobee, pro se.

No appearance required for appellee.

PER CURIAM.

Affirmed. See Wainwright v. State, 411 So. 3d 392 (Fla. 2025), cert. denied sub nom. Wainwright v. Florida, 2025 WL 1621505 (2025) (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), review granted, No. SC2023-1184, 2024 WL 1796831 (Fla. Apr. 25, 2024).

MAY, GERBER and KLINGENSMITH, JJ., concur.

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