Background
Carter D. Heuton, proceeding without counsel, appealed from the Circuit Court for Bradford County. The circuit court proceeding was before Judge James M. Colaw.
The First District’s brief opinion does not describe Heuton’s conviction, sentence, claims, or the precise order under review. Its citation indicates that the appeal implicated whether the holding of Erlinger v. United States, 602 U.S. 821 (2024), applies retroactively.
The Court’s Holding
The Florida First District Court of Appeal affirmed the circuit court’s decision in a per curiam opinion. The court relied on Wainwright v. State, 411 So. 3d 392, 399 (Fla. 2025), which states that Erlinger “does not apply retroactively.”
The opinion provided no additional analysis. Judges Bilbrey, M.K. Thomas, and Long concurred in the disposition.
Key Takeaways
- The First District affirmed the lower court’s ruling.
- Under the Florida Supreme Court’s decision in Wainwright, Erlinger does not apply retroactively.
- The opinion does not supply facts or procedural details beyond the court, parties, and basis for affirmance.
Why It Matters
The decision applies Florida Supreme Court precedent foreclosing retroactive reliance on Erlinger. Litigants seeking collateral or other retroactive relief based on that decision face a controlling state-law barrier in Florida courts.
The opinion was designated nonfinal until disposition of any timely and authorized motion under Florida Rules of Appellate Procedure 9.330 or 9.331.