Marcus Roland Maye v. State of Florida

Summary

The Supreme Court of Florida held that claims under Apprendi and its progeny, including Alleyne, are not cognizable in a motion to correct an illegal sentence under Florida Rule of Criminal Procedure 3.800(a). The court receded from Plott v. State and approved the result of the Sixth District Court of Appeal's decision on that alternative procedural basis, without reaching the constitutionality of Florida's Prison Releasee Reoffender statute.

Holdings

1. An Apprendi claim, including an Alleyne claim, is not cognizable as an illegal-sentence claim under Florida Rule of Criminal Procedure 3.800(a).
2. The court receded from Plott v. State to the extent Plott held that an Apprendi claim is cognizable under Rule 3.800(a).
3. The court did not reach the facial or as-applied constitutionality of the Prison Releasee Reoffender statute because the case could be resolved on the procedural Rule 3.800(a) issue.

Questions Presented

1. Whether an Apprendi or Alleyne claim challenging a sentencing enhancement may be raised at any time through a Florida Rule of Criminal Procedure 3.800(a) motion to correct an illegal sentence.
2. Whether the Supreme Court of Florida should recede from Plott v. State, which held that an Apprendi claim was cognizable under Rule 3.800(a).
3. Whether the court needed to decide the facial or as-applied constitutionality of Florida's Prison Releasee Reoffender statute.

Disposition

approved