Background
Donˈtae N. Williamson, proceeding pro se, appealed from the Circuit Court for Polk County in his criminal case. The appeal proceeded under Florida Rule of Appellate Procedure 9.141(b)(2), which governs certain appeals from summary postconviction rulings.
The Sixth District’s brief opinion does not describe Williamson’s sentence or the specific factual basis of his claim. Its citation to controlling precedent establishes that the appeal concerned an attempt to raise an alleged sentencing error under Apprendi and its progeny through Florida Rule of Criminal Procedure 3.800(a).
The Court’s Holding
The Sixth District affirmed the circuit court’s ruling. Relying on the Florida Supreme Court’s decision in Maye v. State, the court held that Rule 3.800(a) is not the proper procedural vehicle for asserting an alleged error under Apprendi and related cases.
The court also cited Wainwright v. State in support of its disposition. The per curiam opinion offered no additional analysis and did not reach the merits of any underlying constitutional sentencing claim.
Key Takeaways
- Florida Rule of Criminal Procedure 3.800(a) cannot be used to raise an alleged error under Apprendi and its progeny.
- The Sixth District applied the Florida Supreme Court’s 2026 decision in Maye v. State.
- The affirmance concerned the procedural vehicle used for the claim, not an adjudication of the underlying constitutional issue on its merits.
Why It Matters
The decision reinforces the procedural limits of Rule 3.800(a) for defendants seeking to challenge sentences on Apprendi-based grounds. Practitioners must select an authorized procedural mechanism and comply with its applicable requirements rather than characterize such a claim as one correctable under Rule 3.800(a).