Background
In 2005, Aaron Deron Foster was convicted of robbery while actually possessing a firearm. The circuit court sentenced him to life imprisonment as a prison releasee reoffender (PRR), and the Second District previously affirmed his conviction and sentence.
Foster later petitioned for habeas corpus relief, arguing that his confinement was illegal because a jury, rather than a judge, had to determine his eligibility for PRR sentencing. He relied on Erlinger v. United States and Apprendi v. New Jersey. The court noted that Foster had raised the same Apprendi-based argument in a 2010 rule 3.800(a) motion, whose denial was affirmed.
The Court’s Holding
The Second District affirmed the denial of Foster’s habeas petition. Habeas corpus cannot be used as a substitute for an appropriate motion for postconviction relief.
The court also explained that, even if the petition had been treated as another rule 3.800(a) motion, denial remained proper. The Florida Supreme Court recently held that Apprendi and related claims are not cognizable under rule 3.800(a).
Key Takeaways
- A habeas petition cannot substitute for the proper postconviction procedure.
- Foster had previously litigated the same Apprendi-based challenge to his PRR sentence.
- Apprendi-progeny claims are not cognizable under Florida Rule of Criminal Procedure 3.800(a).
Why It Matters
The decision reinforces the procedural limits on collateral sentencing challenges in Florida. Defendants challenging PRR sentences on Apprendi-based theories cannot use habeas corpus to bypass postconviction rules, and rule 3.800(a) does not provide a vehicle for those claims.