Background
Reginald Leon Streeter appealed from the Circuit Court for Polk County in a criminal case originating in 2013. The appeal proceeded under Florida Rule of Appellate Procedure 9.141(b)(2), which governs certain appeals from summary postconviction orders.
Streeter sought relief based on an alleged sentencing error under Apprendi v. New Jersey and its progeny. He raised the claim through Florida Rule of Criminal Procedure 3.800(a), which permits correction of an illegal sentence.
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 the Florida Supreme Court’s decision in Maye v. State, 436 So. 3d 416, 418 (Fla. 2026).
Under Maye, Rule 3.800(a) is not the proper procedural vehicle for asserting a claim of error under Apprendi and related decisions. The Sixth District therefore left the lower court’s disposition undisturbed.
Key Takeaways
- A claim under Apprendi and its progeny cannot be raised through a Rule 3.800(a) motion.
- The Sixth District applied the Florida Supreme Court’s 2026 decision in Maye v. State.
- The court affirmed without separately analyzing the merits of Streeter’s alleged sentencing error.
Why It Matters
The decision reinforces the procedural limits of Rule 3.800(a). Florida defendants and postconviction counsel must select an authorized procedural mechanism for constitutional sentencing claims rather than treating every alleged sentencing defect as an illegal sentence correctable under that rule.
The opinion also shows that Florida appellate courts are applying Maye to foreclose Rule 3.800(a) as a vehicle for Apprendi-based claims.