Background
Breon Brown appealed his criminal conviction from the Circuit Court for the Seventeenth Judicial Circuit in Broward County. The trial court, presided over by Judge Lorena V. Mastrarrigo, rendered the initial judgment in case no. 062020CF001859A88810. Brown was represented on appeal by the Public Defender’s Office, asserting grounds for reversal.
The Court’s Holding
The Fourth District Court of Appeal issued a per curiam decision affirming the trial court’s judgment in its entirety. The court applied controlling precedent from Guzman v. State, 350 So. 3d 72 (Fla. 4th DCA 2022), which itself survived appellate review and denial of certiorari. The affirmance reflects the appellate court’s conclusion that the trial court properly applied binding law.
Key Takeaways
- Criminal convictions in the Fourth District remain subject to Guzman‘s controlling standard on appeal.
- Per curiam affirmances citing established precedent indicate no reversible error warranting discussion or factual elaboration.
- The decision is not final pending disposition of any timely-filed motion for rehearing.
Why It Matters
Guzman has become controlling law in the Fourth District and has withstood both appellate and certiorari review. Brown’s affirmance confirms continued application of that precedent to criminal convictions in the circuit.