Jett v. State of Florida

Summary

The First District Court of Appeal of Florida affirmed Dalton Reid Jett’s judgment and sentence for burglary of a dwelling and grand theft. The court held that any Alleyne error in determining Jett’s prison releasee reoffender status without submitting the issue to a jury was harmless beyond a reasonable doubt because uncontroverted evidence established his qualifying prior release and identity. A concurrence discussed whether the alleged sentencing error was preserved under Florida law.

Holdings

1. Any error in failing to submit to a jury the determination that Jett committed the burglary within three years of his release from a prior term of imprisonment was harmless beyond a reasonable doubt.

Questions Presented

1. Whether the trial court violated Alleyne by determining, rather than submitting to a jury, the fact that Jett committed the burglary within three years of release from a prior term of imprisonment for purposes of the prison releasee reoffender sentencing enhancement.
2. Whether any Alleyne error was harmless beyond a reasonable doubt.

Disposition

affirmed