PHILIPPE BIEN-AIME
v.
STATE OF FLORIDA

Fla. 3d DCA | 2025-12-10
No. 2024-0656
Scales, C.J., Logue, J., Gordo, J., Martinez, J.
2025 FL 11681 Florida District Court of Appeal, Third District (2025)

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Holding

A trial court commits no fundamental error in sentencing when it considers uncharged offenses but imposes a sentence within the permissible range based on the charged offense and prior criminal record.

Headnotes

[1] A trial court does not commit fundamental error in sentencing by hearing evidence regarding uncharged offenses if the record demonstrates the court did not give weight to…

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Key Quotes

“despite trial court hearing about uncharged offenses, the trial court did not commit fundamental error where the record reflects the trial court did not give any weight to the uncharged conduct, and where the trial court had before it evidence concerning the circumstances surrounding the charged offense and the defendant's prior criminal record when imposing a sentence within the permissible range”

Court's application of State v. Garcia standard for sentencing error
Facts & Procedural History

Philippe Bien-Aime appealed his conviction and sentence from Miami-Dade County Court. The trial court held a hearing regarding uncharged offenses duri…

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Opinion of the Court
Scales

Third District Court of Appeal State of Florida

Opinion filed December 10, 2025. Not final until disposition of timely filed motion for rehearing.

________________

No. 3D24-0656 Lower Tribunal Nos. M23-20772, AIMA2KE, A5D6ZUP, AIMCDOE ________________

Philippe Bien-Aime, Appellant,

vs.

State of Florida, Appellee.

An Appeal from the County Court for Miami-Dade County, Lizzet Martinez, Judge.

Carlos J. Martinez, Public Defender, and Deborah Prager, Assistant Public Defender, for appellant.

James Uthmeier, Attorney General, and Daniel Colmenares, Assistant Attorney General, for appellee.

Before SCALES, C.J., and LOGUE and GORDO, JJ.

PER CURIAM.

Affirmed. See State v. Garcia, 346 So. 3d 581, 586 (Fla. 2022) (holding

Footnotes
2 that, despite trial court hearing about uncharged offenses, the trial court did not commit fundamental error where the record reflects the trial court did not give any weight to the uncharged conduct, and where the trial court had before it evidence concerning the circumstances surrounding the charged offense and the defendant’s prior criminal record when imposing a sentence within the permissible range).

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