EDWARD LEE WILSON
v.
STATE OF FLORIDA

Fla. 6th DCA | 2026-10-02
No. 2025-1780
Kyle, J., Stargel, J., White, J., Smith, J.
2026 FL 13055 Florida District Court of Appeal, Sixth District (2026)

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Holding

Rule 3.800(a) is not the proper vehicle for raising Apprendi claims challenging judicial fact-finding that increases a sentence.


Headnotes

[1] Rule 3.800(a) is not the proper procedural vehicle for raising Apprendi claims challenging judicial fact-finding that increases a sentence beyond the statutory maximum.

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Facts & Procedural History

Edward Lee Wilson appealed from a conviction and sentence imposed by the Circuit Court for Lee County.…

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Opinion of the Court

SIXTH DISTRICT COURT OF APPEAL

STATE OF FLORIDA

Case No. 6D2025-1780 Lower Tribunal No. 1990-CF-002153

EDWARD LEE WILSON,

Appellant, v.

STATE OF FLORIDA,

Appellee.

Appeal pursuant to Fla. R. App. P. 9.141(b)(2) from the Circuit Court for Lee County. Bruce Kyle, Judge.

October 2, 2026

PER CURIAM.

AFFIRMED. See Maye v. State, 436 So. 3d 416, 418 (Fla. 2026) (“[R]ule 3.800(a) is not the proper vehicle for raising a claim of error under Apprendi and its progeny, including Alleyne (‘Apprendi claims'). In so holding, we recede from Plott v. State, 148 So. 3d 90 (Fla. 2014), and its contrary holding that an Apprendi claim is cognizable under rule 3.800(a).").

STARGEL, WHITE and SMITH, JJ., concur.

Edward Lee Wilson, Port St. Lucie, pro se.

James Uthmeier, Attorney General, Tallahassee, and Marilyn Frances Muir, Chief Assistant Attorney General, Tampa, for Appellee.


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