WILL UTILE
v.
THE STATE OF FLORIDA
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Will Utile appealed a probation revocation decision by filing a motion to correct illegal sentence under Florida Rule 3.800(a), challenging the sufficiency of evidence supporting the revocation. The Third District Court of Appeal affirmed the lower court's decision, holding that attacks on the sufficiency of evidence for probation revocation are not cognizable under Rule 3.800(a) motions.
A motion to correct illegal sentence under Rule 3.800(a) is not cognizable when the defendant seeks to challenge the sufficiency of evidence supporting a probation revocation, as this type of challenge goes beyond correcting an illegal sentence and instead attacks the validity of the revocation itself.
[1] A motion to correct an illegal sentence under Florida Rule of Appellate Procedure 3.800(a) is not the appropriate vehicle to challenge the sufficiency of the evidence sup…
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Join FLexlaw to unlock all legal intelligence“A motion to correct illegal sentence under rule 3.800(a) is not cognizable where, as here, the defendant seeks to challenge the validity of the conviction and, only by extension, the 'legality' of the resulting sentence.”
Establishes that Rule 3.800(a) motions cannot be used to attack the validity of convictions or sentences that derive their illegality from invalid convictions.
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Join FLexlaw to unlock all legal intelligenceWill Utile was subject to probation in Miami-Dade County. A probation revocation proceeding resulted in an unfavorable determination against Utile. Ut…
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Opinion filed October 16, 2024. Not final until disposition of timely filed motion for rehearing.
________________ No. 3D23-2130 Lower Tribunal No. F06-29278B ________________
Will Utile,
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, Ramiro C. Areces, Judge. Will Utile, in proper person. Ashley Moody, Attorney General, and Richard L. Polin, Assistant Attorney General, for appellee. Before SCALES, LINDSEY, and MILLER, JJ. PER CURIAM.
“A motion to correct illegal sentence under rule 3.800(a) is not cognizable where, as here, the defendant seeks to challenge the validity of the conviction and, only by extension, the ‘legality’ of the resulting sentence.”
Ramirez v. State, 374 So. 3d 71, 72 (Fla. 3d DCA 2022). Although the instant challenge is to the sufficiency of evidence to support the revocation of probation as opposed to the original “conviction,” the same principles apply. See Prince v. State, 903 So. 2d 1068, 1069 (Fla. 2d DCA 2005) (holding that an attack on the sufficiency of the evidence for the probation revocation is not cognizable in a rule 3.800(a) motion).
Affirmed.
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Citator
Cited By
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Will Utile v. State, 374 So. 3d 71 (Fla. 3d DCA 2024)…“A motion to correct illegal sentence under rule 3.800(a) is not cognizable where, as here, the defendant seeks to challenge the validity of 2 the conviction and, only by extension, the ‘legality’ of the resulting sentence.” Ramirez v. State, 374 So. 3d 71, 72 (Fla. 3d DCA 2022). Although the instant challenge is to the sufficiency of evidence to support the revocation of probation as opposed to the original “conviction,” the same principles apply. See Prince v. State, 903 So. 2d 1068, 1069 (Fla.…
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Smith v. State (Fla. 3d DCA 2024)…Procedure 3.850. However, a postconviction challenge to the validity of the underlying conviction cannot form the basis for a claim that the “invalid” conviction rendered the resulting sentence “illegal” under rule 3.800(a). Ramirez v. State, 374 So. 3d 71, 72 (Fla. 3d DCA 2022) (“A motion to correct illegal sentence under rule 3.800(a) is not cognizable where, as here, the defendant seeks to challenge the validity of the conviction and, only by extension, the ‘legality’ of the resulting sentence.…
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Chance Dawkins v. State (Fla. 3d DCA 2025)
Authorities Cited
- Prince v. State, 903 So. 2d 1068 (Fla. 2d DCA 2005)
- Will Utile v. State, 374 So. 3d 71 (Fla. 3d DCA 2024)