Background
William E. Schildgen, proceeding pro se, appealed from the Circuit Court for Lee County, where Judge Bruce Kyle presided over the underlying criminal case.
The appeal proceeded under Florida Rule of Appellate Procedure 9.141(b)(2). The Sixth District’s brief opinion indicates that Schildgen sought relief under Florida Rule of Criminal Procedure 3.800(a) based on Apprendi and its progeny.
The Court’s Holding
The Sixth District Court of Appeal affirmed the circuit court’s ruling.
Citing the Florida Supreme Court’s decision in Maye v. State, 436 So. 3d 416, 418 (Fla. 2026), the court applied the rule that Rule 3.800(a) is not the proper vehicle for raising a claim of error under Apprendi and its progeny.
Key Takeaways
- Florida Rule of Criminal Procedure 3.800(a) is not the proper vehicle for an Apprendi-based claim of error.
- The Sixth District relied on the Florida Supreme Court’s 2026 decision in Maye v. State.
- The court affirmed the circuit court without additional factual or legal analysis.
Why It Matters
The decision reinforces Maye’s procedural limitation on using Rule 3.800(a) to present claims under Apprendi and related decisions.