Background
Stephan Laboy appealed from the Circuit Court for Osceola County, where Judge John D.W. Beamer presided. The appeal proceeded under Florida Rule of Appellate Procedure 9.141(b)(2), which governs certain appeals from summary postconviction orders.
Laboy, proceeding pro se, sought relief under Florida Rule of Criminal Procedure 3.800(a) based on a claimed sentencing error under Apprendi and its progeny. The State made no appearance in the appeal.
The Court’s Holding
The Sixth District Court of Appeal affirmed the circuit court’s ruling in a per curiam opinion.
The court relied on Maye v. State, 51 Fla. L. Weekly S116, S116 (Fla. May 14, 2026), which held that Rule 3.800(a) is not the proper vehicle for raising a claim of error under Apprendi and its progeny, including Alleyne.
Key Takeaways
- Florida Rule of Criminal Procedure 3.800(a) cannot be used to raise sentencing claims under Apprendi and related decisions.
- The Sixth District applied the Florida Supreme Court’s 2026 decision in Maye v. State.
- The court affirmed without further analysis in a brief per curiam opinion.
Why It Matters
The decision reinforces the procedural limitation recognized in Maye: defendants cannot use Rule 3.800(a) as the mechanism for asserting alleged sentencing errors under Apprendi, Alleyne, or their progeny.