Witt test (Florida) · Go Syfert
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Witt test in Florida

44 Florida opinions name it 2 courts 1982–2024 1 in the last five years

The cases below were cited by Florida courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (41)

CaseFollowedCited
State v. Stevensgreen
fla · 1998 · cited in 6 Florida opinions naming this issue, 2001–2006
2 sentences

2006See, e.g., Hughes v. State, 901 So.2d 837, 846 (Fla.2005) (holding that the United States Supreme Court's decision in Apprendi v. New Jersey, 530 U.S. 466 , 120 S.Ct. 2348 , 147 L.Ed.2d 435 (2000), does not apply retroactively under Witt); Johnson v. State, 904 So.2d 400, 412 (Fla.2005) (concluding that the United States Supreme Court’s decision in Ring v. Arizona, 536 U.S. 584 , 122 S.Ct. 2428 , 153 L.Ed.2d 556 (2002), does not satisfy the Witt standard for retroactive application); State v. Klayman, 835 So.2d 248, 254 (Fla.2002) (deciding that the decision in Hayes v. State, 750 So.2d 1 (Fla

2006See, e.g., Hughes v. State, 901 So.2d 837, 846 (Fla.2005) (holding that the United States Supreme Court's decision in Apprendi v. New Jersey, 530 U.S. 466 , 120 S.Ct. 2348 , 147 L.Ed.2d 435 (2000), does not apply retroactively under Witt); Johnson v. State, 904 So.2d 400, 412 (Fla.2005) (concluding that the United States Supreme Court’s decision in Ring v. Arizona, 536 U.S. 584 , 122 S.Ct. 2428 , 153 L.Ed.2d 556 (2002), does not satisfy the Witt standard for retroactive application); State v. Klayman, 835 So.2d 248, 254 (Fla.2002) (deciding that the decision in Hayes v. State, 750 So.2d 1 (Fla

66
Witt v. Stategreen
fla · 1980 · cited in 17 Florida opinions naming this issue, 1995–2024
2 sentences

2024The Witt analysis starts with the understanding that a change of law does not apply retroactively “unless the change: (a) emanates from this Court or the United States Supreme Court, (b) is constitutional in nature, and (c) constitutes a development of fundamental significance.” Id. at 931 .

2024The Witt analysis starts with the understanding that a change of law does not apply retroactively “unless the change: (a) emanates from this Court or the United States Supreme Court, (b) is constitutional in nature, and (c) constitutes a development of fundamental significance.” Id. at 931 .

517
State v. Callawaygreen
fla · 1995 · cited in 8 Florida opinions naming this issue, 1996–2013
2 sentences

2013The Effect on the Administration of Justice of a Retroactive Application of the New Rule The Florida Supreme Court has held that, in undertaking a Witt analysis to determine retroactive application of a new rule, “the fundamental consideration is the balancing of the need for decisional finality against the concern for fairness and uniformity in individual cases.” Johnson v. State, 904 So.2d 400, 408 (quoting State v. Callaway, 658 So.2d 983, 986 (Fla.1995)).

2013The Effect on the Administration of Justice of a Retroactive Application of the New Rule The Florida Supreme Court has held that, in undertaking a Witt analysis to determine retroactive application of a new rule, “the fundamental consideration is the balancing of the need for decisional finality against the concern for fairness and uniformity in individual cases.” Johnson v. State, 904 So.2d 400, 408 (quoting State v. Callaway, 658 So.2d 983, 986 (Fla.1995)).

58
Johnson v. Stategreen
fla · 2005 · cited in 7 Florida opinions naming this issue, 2005–2016
2 sentences

2013The Effect on the Administration of Justice of a Retroactive Application of the New Rule The Florida Supreme Court has held that, in undertaking a Witt analysis to determine retroactive application of a new rule, “the fundamental consideration is the balancing of the need for decisional finality against the concern for fairness and uniformity in individual cases.” Johnson v. State, 904 So.2d 400, 408 (quoting State v. Callaway, 658 So.2d 983, 986 (Fla.1995)).

2013The Effect on the Administration of Justice of a Retroactive Application of the New Rule The Florida Supreme Court has held that, in undertaking a Witt analysis to determine retroactive application of a new rule, “the fundamental consideration is the balancing of the need for decisional finality against the concern for fairness and uniformity in individual cases.” Johnson v. State, 904 So.2d 400, 408 (quoting State v. Callaway, 658 So.2d 983, 986 (Fla.1995)).

57
Hughes v. Stategreen
fla · 2005 · cited in 7 Florida opinions naming this issue, 2006–2016
2 sentences

2016In its analysis of retroactivity, the majority gives a wave-of-the-hand dismissal to the carefully reasoned decision in Johnson.25 Our decision in Johnson followed the trajectory established by our earlier decision in Hughes v. State, 901 So. 2d 837 (Fla. 2005), which applied a Witt analysis to conclude that the decision in Apprendi26—which unquestionably spawned both Ring and Hurst v. Florida— should not be applied retroactively.

2016In its analysis of retroactivity, the majority gives a wave-of-the-hand dismissal to the carefully reasoned decision in Johnson.25 Our decision in Johnson followed the trajectory established by our earlier decision in Hughes v. State, 901 So. 2d 837 (Fla. 2005), which applied a Witt analysis to conclude that the decision in Apprendi26—which unquestionably spawned both Ring and Hurst v. Florida— should not be applied retroactively.

47
Ferguson v. Stategreen
fla · 2001 · cited in 4 Florida opinions naming this issue, 2005–2016
2 sentences

2006See, e.g., Hughes v. State, 901 So.2d 837, 846 (Fla.2005) (holding that the United States Supreme Court's decision in Apprendi v. New Jersey, 530 U.S. 466 , 120 S.Ct. 2348 , 147 L.Ed.2d 435 (2000), does not apply retroactively under Witt); Johnson v. State, 904 So.2d 400, 412 (Fla.2005) (concluding that the United States Supreme Court’s decision in Ring v. Arizona, 536 U.S. 584 , 122 S.Ct. 2428 , 153 L.Ed.2d 556 (2002), does not satisfy the Witt standard for retroactive application); State v. Klayman, 835 So.2d 248, 254 (Fla.2002) (deciding that the decision in Hayes v. State, 750 So.2d 1 (Fla

2006See, e.g., Hughes v. State, 901 So.2d 837, 846 (Fla.2005) (holding that the United States Supreme Court's decision in Apprendi v. New Jersey, 530 U.S. 466 , 120 S.Ct. 2348 , 147 L.Ed.2d 435 (2000), does not apply retroactively under Witt); Johnson v. State, 904 So.2d 400, 412 (Fla.2005) (concluding that the United States Supreme Court’s decision in Ring v. Arizona, 536 U.S. 584 , 122 S.Ct. 2428 , 153 L.Ed.2d 556 (2002), does not satisfy the Witt standard for retroactive application); State v. Klayman, 835 So.2d 248, 254 (Fla.2002) (deciding that the decision in Hayes v. State, 750 So.2d 1 (Fla

44
McCuiston v. Stategreen
fla · 1988 · cited in 4 Florida opinions naming this issue, 2002–2006
2 sentences

2006See, e.g., Hughes v. State, 901 So.2d 837, 846 (Fla.2005) (holding that the United States Supreme Court's decision in Apprendi v. New Jersey, 530 U.S. 466 , 120 S.Ct. 2348 , 147 L.Ed.2d 435 (2000), does not apply retroactively under Witt); Johnson v. State, 904 So.2d 400, 412 (Fla.2005) (concluding that the United States Supreme Court’s decision in Ring v. Arizona, 536 U.S. 584 , 122 S.Ct. 2428 , 153 L.Ed.2d 556 (2002), does not satisfy the Witt standard for retroactive application); State v. Klayman, 835 So.2d 248, 254 (Fla.2002) (deciding that the decision in Hayes v. State, 750 So.2d 1 (Fla

2006See, e.g., Hughes v. State, 901 So.2d 837, 846 (Fla.2005) (holding that the United States Supreme Court's decision in Apprendi v. New Jersey, 530 U.S. 466 , 120 S.Ct. 2348 , 147 L.Ed.2d 435 (2000), does not apply retroactively under Witt); Johnson v. State, 904 So.2d 400, 412 (Fla.2005) (concluding that the United States Supreme Court’s decision in Ring v. Arizona, 536 U.S. 584 , 122 S.Ct. 2428 , 153 L.Ed.2d 556 (2002), does not satisfy the Witt standard for retroactive application); State v. Klayman, 835 So.2d 248, 254 (Fla.2002) (deciding that the decision in Hayes v. State, 750 So.2d 1 (Fla

44
State v. Glenngreen
fla · 1990 · cited in 4 Florida opinions naming this issue, 1994–2006
2 sentences

2006See, e.g., Hughes v. State, 901 So.2d 837, 846 (Fla.2005) (holding that the United States Supreme Court's decision in Apprendi v. New Jersey, 530 U.S. 466 , 120 S.Ct. 2348 , 147 L.Ed.2d 435 (2000), does not apply retroactively under Witt); Johnson v. State, 904 So.2d 400, 412 (Fla.2005) (concluding that the United States Supreme Court’s decision in Ring v. Arizona, 536 U.S. 584 , 122 S.Ct. 2428 , 153 L.Ed.2d 556 (2002), does not satisfy the Witt standard for retroactive application); State v. Klayman, 835 So.2d 248, 254 (Fla.2002) (deciding that the decision in Hayes v. State, 750 So.2d 1 (Fla

2006See, e.g., Hughes v. State, 901 So.2d 837, 846 (Fla.2005) (holding that the United States Supreme Court's decision in Apprendi v. New Jersey, 530 U.S. 466 , 120 S.Ct. 2348 , 147 L.Ed.2d 435 (2000), does not apply retroactively under Witt); Johnson v. State, 904 So.2d 400, 412 (Fla.2005) (concluding that the United States Supreme Court’s decision in Ring v. Arizona, 536 U.S. 584 , 122 S.Ct. 2428 , 153 L.Ed.2d 556 (2002), does not satisfy the Witt standard for retroactive application); State v. Klayman, 835 So.2d 248, 254 (Fla.2002) (deciding that the decision in Hayes v. State, 750 So.2d 1 (Fla

34
State v. Iacovonegreen
fla · 1995 · cited in 5 Florida opinions naming this issue, 1998–2006
2 sentences

2006See, e.g., Hughes v. State, 901 So.2d 837, 846 (Fla.2005) (holding that the United States Supreme Court's decision in Apprendi v. New Jersey, 530 U.S. 466 , 120 S.Ct. 2348 , 147 L.Ed.2d 435 (2000), does not apply retroactively under Witt); Johnson v. State, 904 So.2d 400, 412 (Fla.2005) (concluding that the United States Supreme Court’s decision in Ring v. Arizona, 536 U.S. 584 , 122 S.Ct. 2428 , 153 L.Ed.2d 556 (2002), does not satisfy the Witt standard for retroactive application); State v. Klayman, 835 So.2d 248, 254 (Fla.2002) (deciding that the decision in Hayes v. State, 750 So.2d 1 (Fla

2006See, e.g., Hughes v. State, 901 So.2d 837, 846 (Fla.2005) (holding that the United States Supreme Court's decision in Apprendi v. New Jersey, 530 U.S. 466 , 120 S.Ct. 2348 , 147 L.Ed.2d 435 (2000), does not apply retroactively under Witt); Johnson v. State, 904 So.2d 400, 412 (Fla.2005) (concluding that the United States Supreme Court’s decision in Ring v. Arizona, 536 U.S. 584 , 122 S.Ct. 2428 , 153 L.Ed.2d 556 (2002), does not satisfy the Witt standard for retroactive application); State v. Klayman, 835 So.2d 248, 254 (Fla.2002) (deciding that the decision in Hayes v. State, 750 So.2d 1 (Fla

25
State v. Klaymangreen
fla · 2002 · cited in 4 Florida opinions naming this issue, 2002–2006
2 sentences

2006See, e.g., Hughes v. State, 901 So.2d 837, 846 (Fla.2005) (holding that the United States Supreme Court's decision in Apprendi v. New Jersey, 530 U.S. 466 , 120 S.Ct. 2348 , 147 L.Ed.2d 435 (2000), does not apply retroactively under Witt); Johnson v. State, 904 So.2d 400, 412 (Fla.2005) (concluding that the United States Supreme Court’s decision in Ring v. Arizona, 536 U.S. 584 , 122 S.Ct. 2428 , 153 L.Ed.2d 556 (2002), does not satisfy the Witt standard for retroactive application); State v. Klayman, 835 So.2d 248, 254 (Fla.2002) (deciding that the decision in Hayes v. State, 750 So.2d 1 (Fla

2006See, e.g., Hughes v. State, 901 So.2d 837, 846 (Fla.2005) (holding that the United States Supreme Court's decision in Apprendi v. New Jersey, 530 U.S. 466 , 120 S.Ct. 2348 , 147 L.Ed.2d 435 (2000), does not apply retroactively under Witt); Johnson v. State, 904 So.2d 400, 412 (Fla.2005) (concluding that the United States Supreme Court’s decision in Ring v. Arizona, 536 U.S. 584 , 122 S.Ct. 2428 , 153 L.Ed.2d 556 (2002), does not satisfy the Witt standard for retroactive application); State v. Klayman, 835 So.2d 248, 254 (Fla.2002) (deciding that the decision in Hayes v. State, 750 So.2d 1 (Fla

24
Delgado v. Statered
fla · 2000 · cited in 3 Florida opinions naming this issue, 2001–2005
2 sentences

2004Compare State v. Stevens, 714 So.2d 347 (Fla.1998) (determining that Court's decision in State v. Iacovone, 660 So.2d 1371 (Fla.1995), which invalidated the statutory penalties for attempted second- and third-degree murder of a law enforcement officer, met all three prongs of Witt and should be applied retroactively) with Delgado v. State, 776 So.2d 233, 241 , 241 n. 7 (Fla.2000) (concluding that Court's interpretation of the burglary statute did not meet the second or third prongs of the Witt test and could not be applied retroactively).

2004Compare State v. Stevens, 714 So.2d 347 (Fla.1998) (determining that Court's decision in State v. Iacovone, 660 So.2d 1371 (Fla.1995), which invalidated the statutory penalties for attempted second- and third-degree murder of a law enforcement officer, met all three prongs of Witt and should be applied retroactively) with Delgado v. State, 776 So.2d 233, 241 , 241 n. 7 (Fla.2000) (concluding that Court's interpretation of the burglary statute did not meet the second or third prongs of the Witt test and could not be applied retroactively).

23
Stovall v. Dennogreen
scotus · 1967 · cited in 7 Florida opinions naming this issue, 1998–2024
2 sentences

2020Regarding the third prong of the Witt analysis, a decision is of fundamental significance when it either (1) places beyond the authority of the state the power to regulate certain conduct or to impose certain penalties or (2) when the rule is of sufficient magnitude to necessitate retroactive application under the retroactivity test of Stovall v. Denno, 388 U.S. 293, 297 (1967), and Linkletter v. Walker, 381 U.S. 618, 636 (1965).

2020Regarding the third prong of the Witt analysis, a decision is of fundamental significance when it either (1) places beyond the authority of the state the power to regulate certain conduct or to impose certain penalties or (2) when the rule is of sufficient magnitude to necessitate retroactive application under the retroactivity test of Stovall v. Denno, 388 U.S. 293, 297 (1967), and Linkletter v. Walker, 381 U.S. 618, 636 (1965).

17
Hale v. Stategreen
fla · 1993 · cited in 7 Florida opinions naming this issue, 1996–2006
2 sentences

2006See, e.g., Hughes v. State, 901 So.2d 837, 846 (Fla.2005) (holding that the United States Supreme Court's decision in Apprendi v. New Jersey, 530 U.S. 466 , 120 S.Ct. 2348 , 147 L.Ed.2d 435 (2000), does not apply retroactively under Witt); Johnson v. State, 904 So.2d 400, 412 (Fla.2005) (concluding that the United States Supreme Court’s decision in Ring v. Arizona, 536 U.S. 584 , 122 S.Ct. 2428 , 153 L.Ed.2d 556 (2002), does not satisfy the Witt standard for retroactive application); State v. Klayman, 835 So.2d 248, 254 (Fla.2002) (deciding that the decision in Hayes v. State, 750 So.2d 1 (Fla

2006See, e.g., Hughes v. State, 901 So.2d 837, 846 (Fla.2005) (holding that the United States Supreme Court's decision in Apprendi v. New Jersey, 530 U.S. 466 , 120 S.Ct. 2348 , 147 L.Ed.2d 435 (2000), does not apply retroactively under Witt); Johnson v. State, 904 So.2d 400, 412 (Fla.2005) (concluding that the United States Supreme Court’s decision in Ring v. Arizona, 536 U.S. 584 , 122 S.Ct. 2428 , 153 L.Ed.2d 556 (2002), does not satisfy the Witt standard for retroactive application); State v. Klayman, 835 So.2d 248, 254 (Fla.2002) (deciding that the decision in Hayes v. State, 750 So.2d 1 (Fla

17
Apprendi v. New Jerseygreen
scotus · 2000 · cited in 4 Florida opinions naming this issue, 2005–2011
2 sentences

2011In Hughes v. State, 901 So.2d 837 (Fla.2005), the Supreme Court of Florida used the Witt standard to assess whether Apprendi v. New Jersey, 530 U.S. 466 , 120 S.Ct. 2348 , 147 L.Ed.2d 435 (2000), should be applied retroactively.

2011In Hughes v. State, 901 So.2d 837 (Fla.2005), the Supreme Court of Florida used the Witt standard to assess whether Apprendi v. New Jersey, 530 U.S. 466 , 120 S.Ct. 2348 , 147 L.Ed.2d 435 (2000), should be applied retroactively.

14
Dixon v. Stategreen
fla · 1999 · cited in 4 Florida opinions naming this issue, 2004–2006
2 sentences

2006See, e.g., Hughes v. State, 901 So.2d 837, 846 (Fla.2005) (holding that the United States Supreme Court's decision in Apprendi v. New Jersey, 530 U.S. 466 , 120 S.Ct. 2348 , 147 L.Ed.2d 435 (2000), does not apply retroactively under Witt); Johnson v. State, 904 So.2d 400, 412 (Fla.2005) (concluding that the United States Supreme Court’s decision in Ring v. Arizona, 536 U.S. 584 , 122 S.Ct. 2428 , 153 L.Ed.2d 556 (2002), does not satisfy the Witt standard for retroactive application); State v. Klayman, 835 So.2d 248, 254 (Fla.2002) (deciding that the decision in Hayes v. State, 750 So.2d 1 (Fla

2006See, e.g., Hughes v. State, 901 So.2d 837, 846 (Fla.2005) (holding that the United States Supreme Court's decision in Apprendi v. New Jersey, 530 U.S. 466 , 120 S.Ct. 2348 , 147 L.Ed.2d 435 (2000), does not apply retroactively under Witt); Johnson v. State, 904 So.2d 400, 412 (Fla.2005) (concluding that the United States Supreme Court’s decision in Ring v. Arizona, 536 U.S. 584 , 122 S.Ct. 2428 , 153 L.Ed.2d 556 (2002), does not satisfy the Witt standard for retroactive application); State v. Klayman, 835 So.2d 248, 254 (Fla.2002) (deciding that the decision in Hayes v. State, 750 So.2d 1 (Fla

14
Teague v. Lanegreen
scotus · 1989 · cited in 3 Florida opinions naming this issue, 2005–2013
2 sentences

2013I recognize of course that the United States Supreme Court and the federal courts determine the question of retroactivity by applying the standard established in Teague, 489 U.S. at 310 , 109 S.Ct. 1060 (1989), while Florida courts continue to apply the Witt standard.

2013I recognize of course that the United States Supreme Court and the federal courts determine the question of retroactivity by applying the standard established in Teague, 489 U.S. at 310 , 109 S.Ct. 1060 (1989), while Florida courts continue to apply the Witt standard.

13
Callaway v. Stategreen
fladistctapp · 1994 · cited in 2 Florida opinions naming this issue, 1997–2019
2 sentences

2019See Callaway v. State, 642 So. 2d 636, 641 (Fla. 2d DCA 1994) (discussing why a Witt analysis may not apply to a rule 3.800(a) claim).

2019See Callaway v. State, 642 So. 2d 636, 641 (Fla. 2d DCA 1994) (discussing why a Witt analysis may not apply to a rule 3.800(a) claim).

12
Chandler v. Crosbygreen
fla · 2005 · cited in 1 Florida opinions naming this issue, 2024–2024
2 sentences

2024See Asay, 210 So. 3d at 19-20 (concluding the Court’s extensive reliance on the old rule, “spann[ing] decades’ worth of capital cases,” “weigh[ed] heavily - 15 - against retroactive application” of the new rule); Chandler, 916 So. 2d at 730 (concluding the Witt factors weighed against retroactive application in part because the old rule “was relied on by trial courts for over 20 years”); Williams, 421 So. 2d at 515 (“That significant reliance has been placed on the old rule is an important factor supporting prospective application of the new rule.”).

2024See Asay, 210 So. 3d at 19-20 (concluding the Court’s extensive reliance on the old rule, “spann[ing] decades’ worth of capital cases,” “weigh[ed] heavily - 15 - against retroactive application” of the new rule); Chandler, 916 So. 2d at 730 (concluding the Witt factors weighed against retroactive application in part because the old rule “was relied on by trial courts for over 20 years”); Williams, 421 So. 2d at 515 (“That significant reliance has been placed on the old rule is an important factor supporting prospective application of the new rule.”).

11
Williams v. Stategreen
fla · 1982 · cited in 1 Florida opinions naming this issue, 2024–2024
2 sentences

2024See Asay, 210 So. 3d at 19-20 (concluding the Court’s extensive reliance on the old rule, “spann[ing] decades’ worth of capital cases,” “weigh[ed] heavily - 15 - against retroactive application” of the new rule); Chandler, 916 So. 2d at 730 (concluding the Witt factors weighed against retroactive application in part because the old rule “was relied on by trial courts for over 20 years”); Williams, 421 So. 2d at 515 (“That significant reliance has been placed on the old rule is an important factor supporting prospective application of the new rule.”).

2024See Asay, 210 So. 3d at 19-20 (concluding the Court’s extensive reliance on the old rule, “spann[ing] decades’ worth of capital cases,” “weigh[ed] heavily - 15 - against retroactive application” of the new rule); Chandler, 916 So. 2d at 730 (concluding the Witt factors weighed against retroactive application in part because the old rule “was relied on by trial courts for over 20 years”); Williams, 421 So. 2d at 515 (“That significant reliance has been placed on the old rule is an important factor supporting prospective application of the new rule.”).

11
Mark James Asay v. State of Florida, SC16-102 Mark James Asay v. Julie L. Jones, etc. & SC16-628 Mark James Asay v. Julie L. Jones, etc.green
fla · 2016 · cited in 1 Florida opinions naming this issue, 2024–2024
2 sentences

2024See Asay, 210 So. 3d at 19-20 (concluding the Court’s extensive reliance on the old rule, “spann[ing] decades’ worth of capital cases,” “weigh[ed] heavily - 15 - against retroactive application” of the new rule); Chandler, 916 So. 2d at 730 (concluding the Witt factors weighed against retroactive application in part because the old rule “was relied on by trial courts for over 20 years”); Williams, 421 So. 2d at 515 (“That significant reliance has been placed on the old rule is an important factor supporting prospective application of the new rule.”).

2024See Asay, 210 So. 3d at 19-20 (concluding the Court’s extensive reliance on the old rule, “spann[ing] decades’ worth of capital cases,” “weigh[ed] heavily - 15 - against retroactive application” of the new rule); Chandler, 916 So. 2d at 730 (concluding the Witt factors weighed against retroactive application in part because the old rule “was relied on by trial courts for over 20 years”); Williams, 421 So. 2d at 515 (“That significant reliance has been placed on the old rule is an important factor supporting prospective application of the new rule.”).

11
Hernandez v. Stategreen
fla · 2012 · cited in 1 Florida opinions naming this issue, 2020–2020
2 sentences

2020See id.; Hernandez v. State, 124 So. 3d 757, 764 (Fla. 2012); Witt, 387 So. 2d at 929 .

2020See id.; Hernandez v. State, 124 So. 3d 757, 764 (Fla. 2012); Witt, 387 So. 2d at 929 .

11
Thomas v. Stategreen
fladistctapp · 2005 · cited in 1 Florida opinions naming this issue, 2019–2019
11
Cotto v. Stategreen
fladistctapp · 2014 · cited in 1 Florida opinions naming this issue, 2019–2019
11
United States v. Orlando Moragreen
ca10 · 2002 · cited in 1 Florida opinions naming this issue, 2016–2016
11
Gonzalez v. Stategreen
fladistctapp · 2012 · cited in 1 Florida opinions naming this issue, 2014–2014
11
Danforth v. Minnesotagreen
scotus · 2008 · cited in 1 Florida opinions naming this issue, 2013–2013
11
Windom v. Stategreen
fla · 2004 · cited in 1 Florida opinions naming this issue, 2013–2013
11
Mortimer v. Stategreen
fladistctapp · 2012 · cited in 1 Florida opinions naming this issue, 2013–2013
11
Heuton v. Stategreen
fladistctapp · 2011 · cited in 1 Florida opinions naming this issue, 2012–2012
11
Fiore v. Whitegreen
scotus · 2001 · cited in 1 Florida opinions naming this issue, 2006–2006
11
Barnum v. Stategreen
fladistctapp · 2003 · cited in 1 Florida opinions naming this issue, 2006–2006
11
Sweeney v. Stategreen
fladistctapp · 1998 · cited in 1 Florida opinions naming this issue, 2006–2006
11
Brown v. Stategreen
fladistctapp · 2002 · cited in 1 Florida opinions naming this issue, 2005–2005
11
Jeffrey P. Curtis and Martin A. Sax v. United Statesgreen
ca7 · 2002 · cited in 1 Florida opinions naming this issue, 2005–2005
11
Monlyn v. Stategreen
fla · 2004 · cited in 1 Florida opinions naming this issue, 2005–2005
11
Cooper v. Stategreen
fla · 2003 · cited in 1 Florida opinions naming this issue, 2004–2004
11
Lawrence v. Stategreen
fla · 2003 · cited in 1 Florida opinions naming this issue, 2004–2004
11
Anderson v. Stategreen
fla · 2003 · cited in 1 Florida opinions naming this issue, 2004–2004
11
Spencer v. Stategreen
fla · 2003 · cited in 1 Florida opinions naming this issue, 2004–2004
11
Caballero v. Stategreen
fla · 2003 · cited in 1 Florida opinions naming this issue, 2004–2004
11

Distinguished, questioned or overruled (1)

CaseNegativeCited
Thomas E. King v. State of Floridagreen
fladistctapp · 2018 · cited in 1 Florida opinions naming this issue, 2019–2019
11

Also cited on this issue (38)

CaseCitedYears
Linkletter v. Walker red
scotus · 1965
2 sentences

2020Regarding the third prong of the Witt analysis, a decision is of fundamental significance when it either (1) places beyond the authority of the state the power to regulate certain conduct or to impose certain penalties or (2) when the rule is of sufficient magnitude to necessitate retroactive application under the retroactivity test of Stovall v. Denno, 388 U.S. 293, 297 (1967), and Linkletter v. Walker, 381 U.S. 618, 636 (1965).

2020Regarding the third prong of the Witt analysis, a decision is of fundamental significance when it either (1) places beyond the authority of the state the power to regulate certain conduct or to impose certain penalties or (2) when the rule is of sufficient magnitude to necessitate retroactive application under the retroactivity test of Stovall v. Denno, 388 U.S. 293, 297 (1967), and Linkletter v. Walker, 381 U.S. 618, 636 (1965).

42005–2020
Ring v. Arizona green
scotus · 2002
2 sentences

2006See, e.g., Hughes v. State, 901 So.2d 837, 846 (Fla.2005) (holding that the United States Supreme Court's decision in Apprendi v. New Jersey, 530 U.S. 466 , 120 S.Ct. 2348 , 147 L.Ed.2d 435 (2000), does not apply retroactively under Witt); Johnson v. State, 904 So.2d 400, 412 (Fla.2005) (concluding that the United States Supreme Court’s decision in Ring v. Arizona, 536 U.S. 584 , 122 S.Ct. 2428 , 153 L.Ed.2d 556 (2002), does not satisfy the Witt standard for retroactive application); State v. Klayman, 835 So.2d 248, 254 (Fla.2002) (deciding that the decision in Hayes v. State, 750 So.2d 1 (Fla

2006See, e.g., Hughes v. State, 901 So.2d 837, 846 (Fla.2005) (holding that the United States Supreme Court's decision in Apprendi v. New Jersey, 530 U.S. 466 , 120 S.Ct. 2348 , 147 L.Ed.2d 435 (2000), does not apply retroactively under Witt); Johnson v. State, 904 So.2d 400, 412 (Fla.2005) (concluding that the United States Supreme Court’s decision in Ring v. Arizona, 536 U.S. 584 , 122 S.Ct. 2428 , 153 L.Ed.2d 556 (2002), does not satisfy the Witt standard for retroactive application); State v. Klayman, 835 So.2d 248, 254 (Fla.2002) (deciding that the decision in Hayes v. State, 750 So.2d 1 (Fla

42005–2011
Carter v. State green
fla · 1997
2 sentences

2006See, e.g., Hughes v. State, 901 So.2d 837, 846 (Fla.2005) (holding that the United States Supreme Court's decision in Apprendi v. New Jersey, 530 U.S. 466 , 120 S.Ct. 2348 , 147 L.Ed.2d 435 (2000), does not apply retroactively under Witt); Johnson v. State, 904 So.2d 400, 412 (Fla.2005) (concluding that the United States Supreme Court’s decision in Ring v. Arizona, 536 U.S. 584 , 122 S.Ct. 2428 , 153 L.Ed.2d 556 (2002), does not satisfy the Witt standard for retroactive application); State v. Klayman, 835 So.2d 248, 254 (Fla.2002) (deciding that the decision in Hayes v. State, 750 So.2d 1 (Fla

2006See, e.g., Hughes v. State, 901 So.2d 837, 846 (Fla.2005) (holding that the United States Supreme Court's decision in Apprendi v. New Jersey, 530 U.S. 466 , 120 S.Ct. 2348 , 147 L.Ed.2d 435 (2000), does not apply retroactively under Witt); Johnson v. State, 904 So.2d 400, 412 (Fla.2005) (concluding that the United States Supreme Court’s decision in Ring v. Arizona, 536 U.S. 584 , 122 S.Ct. 2428 , 153 L.Ed.2d 556 (2002), does not satisfy the Witt standard for retroactive application); State v. Klayman, 835 So.2d 248, 254 (Fla.2002) (deciding that the decision in Hayes v. State, 750 So.2d 1 (Fla

32001–2006
Whitehead v. State green
fla · 1986
2 sentences

2006See, e.g., Hughes v. State, 901 So.2d 837, 846 (Fla.2005) (holding that the United States Supreme Court's decision in Apprendi v. New Jersey, 530 U.S. 466 , 120 S.Ct. 2348 , 147 L.Ed.2d 435 (2000), does not apply retroactively under Witt); Johnson v. State, 904 So.2d 400, 412 (Fla.2005) (concluding that the United States Supreme Court’s decision in Ring v. Arizona, 536 U.S. 584 , 122 S.Ct. 2428 , 153 L.Ed.2d 556 (2002), does not satisfy the Witt standard for retroactive application); State v. Klayman, 835 So.2d 248, 254 (Fla.2002) (deciding that the decision in Hayes v. State, 750 So.2d 1 (Fla

2006See, e.g., Hughes v. State, 901 So.2d 837, 846 (Fla.2005) (holding that the United States Supreme Court's decision in Apprendi v. New Jersey, 530 U.S. 466 , 120 S.Ct. 2348 , 147 L.Ed.2d 435 (2000), does not apply retroactively under Witt); Johnson v. State, 904 So.2d 400, 412 (Fla.2005) (concluding that the United States Supreme Court’s decision in Ring v. Arizona, 536 U.S. 584 , 122 S.Ct. 2428 , 153 L.Ed.2d 556 (2002), does not satisfy the Witt standard for retroactive application); State v. Klayman, 835 So.2d 248, 254 (Fla.2002) (deciding that the decision in Hayes v. State, 750 So.2d 1 (Fla

22006–2006
Hayes v. State green
fla · 1999
2 sentences

2006See, e.g., Hughes v. State, 901 So.2d 837, 846 (Fla.2005) (holding that the United States Supreme Court's decision in Apprendi v. New Jersey, 530 U.S. 466 , 120 S.Ct. 2348 , 147 L.Ed.2d 435 (2000), does not apply retroactively under Witt); Johnson v. State, 904 So.2d 400, 412 (Fla.2005) (concluding that the United States Supreme Court’s decision in Ring v. Arizona, 536 U.S. 584 , 122 S.Ct. 2428 , 153 L.Ed.2d 556 (2002), does not satisfy the Witt standard for retroactive application); State v. Klayman, 835 So.2d 248, 254 (Fla.2002) (deciding that the decision in Hayes v. State, 750 So.2d 1 (Fla

2006See, e.g., Hughes v. State, 901 So.2d 837, 846 (Fla.2005) (holding that the United States Supreme Court's decision in Apprendi v. New Jersey, 530 U.S. 466 , 120 S.Ct. 2348 , 147 L.Ed.2d 435 (2000), does not apply retroactively under Witt); Johnson v. State, 904 So.2d 400, 412 (Fla.2005) (concluding that the United States Supreme Court’s decision in Ring v. Arizona, 536 U.S. 584 , 122 S.Ct. 2428 , 153 L.Ed.2d 556 (2002), does not satisfy the Witt standard for retroactive application); State v. Klayman, 835 So.2d 248, 254 (Fla.2002) (deciding that the decision in Hayes v. State, 750 So.2d 1 (Fla

22006–2006
Carawan v. State red
fla · 1987
2 sentences

2006See, e.g., Hughes v. State, 901 So.2d 837, 846 (Fla.2005) (holding that the United States Supreme Court's decision in Apprendi v. New Jersey, 530 U.S. 466 , 120 S.Ct. 2348 , 147 L.Ed.2d 435 (2000), does not apply retroactively under Witt); Johnson v. State, 904 So.2d 400, 412 (Fla.2005) (concluding that the United States Supreme Court’s decision in Ring v. Arizona, 536 U.S. 584 , 122 S.Ct. 2428 , 153 L.Ed.2d 556 (2002), does not satisfy the Witt standard for retroactive application); State v. Klayman, 835 So.2d 248, 254 (Fla.2002) (deciding that the decision in Hayes v. State, 750 So.2d 1 (Fla

2006See, e.g., Hughes v. State, 901 So.2d 837, 846 (Fla.2005) (holding that the United States Supreme Court's decision in Apprendi v. New Jersey, 530 U.S. 466 , 120 S.Ct. 2348 , 147 L.Ed.2d 435 (2000), does not apply retroactively under Witt); Johnson v. State, 904 So.2d 400, 412 (Fla.2005) (concluding that the United States Supreme Court’s decision in Ring v. Arizona, 536 U.S. 584 , 122 S.Ct. 2428 , 153 L.Ed.2d 556 (2002), does not satisfy the Witt standard for retroactive application); State v. Klayman, 835 So.2d 248, 254 (Fla.2002) (deciding that the decision in Hayes v. State, 750 So.2d 1 (Fla

22006–2006
Bunkley v. State green
fla · 2002
2 sentences

2006Additionally, the district court explained that in deciding the case before it, the court had considered this Court's decisions in Klayman and Bunkley v. State, 833 So.2d 739 (Fla.2002), in which we held that Florida Supreme Court decisions that "clarify" statutory law apply to all cases, pending or final, while decisions that "change" the law require a Witt analysis to determine if the decision should be applied retroactively.

2003In deciding this case, we have considered State v. Klayman, 835 So.2d 248 (Fla.2002), and Bunkley v. State, 833 So.2d 739 (Fla.2002), in which the court explained that supreme court decisions that “clarify” statutory law apply to all cases, pending or final, while decisions that “change” the law require a Witt analysis.

22003–2006
Miller v. Florida green
scotus · 1987
2 sentences

1994Our analysis in this ease appears to be consistent with the First District’s decision to retroactively re-sentence prisoners whose guideline sentences were affected by Miller v. Florida, 482 U.S. 423 , 107 S.Ct. 2446 , 96 L.Ed.2d 351 (1987).

1994Our analysis in this ease appears to be consistent with the First District’s decision to retroactively re-sentence prisoners whose guideline sentences were affected by Miller v. Florida, 482 U.S. 423 , 107 S.Ct. 2446 , 96 L.Ed.2d 351 (1987).

21994–1994
Frank A. Walls v. State of Florida green
fla · 2016
2 sentences

2020In concluding that Hall met the third prong of the Witt analysis, we declared “that Hall warrants retroactive application as a - 10 - development of fundamental significance that places beyond the State of Florida the power to impose a certain sentence—the sentence of death for individuals within a broader range of IQ scores than before.” Walls, 213 So. 3d at 346 .

2020In concluding that Hall met the third prong of the Witt analysis, we declared “that Hall warrants retroactive application as a - 10 - development of fundamental significance that places beyond the State of Florida the power to impose a certain sentence—the sentence of death for individuals within a broader range of IQ scores than before.” Walls, 213 So. 3d at 346 .

12020–2020
Knight v. York, Superintendent, Albemarle Correctional Institution green
scotus · 2002
12016–2016
Bennafield v. United States green
scotus · 2002
12016–2016
Brown v. United States District Court for the Western District of Louisiana green
scotus · 2002
12016–2016
Rebecca Lee Falcon v. State of Florida green
fla · 2015
12016–2016
Barrios-Cruz v. State green
fladistctapp · 2011
12014–2014
Roper v. Simmons green
scotus · 2005
12013–2013
Woodson v. North Carolina green
scotus · 1976
12013–2013
Lockett v. Ohio green
scotus · 1978
12013–2013
Eddings v. Oklahoma green
scotus · 1982
12013–2013
Sumner v. Shuman green
scotus · 1987
12013–2013
Kleppinger v. State green
fladistctapp · 2012
12012–2012
State v. Hearns green
fla · 2007
12008–2008
State v. Barnum green
fla · 2006
12006–2006
DeStefano v. Woods green
scotus · 1968
12005–2005
Figarola v. State green
fladistctapp · 2003
12005–2005
Leonard v. State neutral
fladistctapp · 2005
12005–2005
Nash v. Blumex U. S. A., Inc green
scotus · 2003
12004–2004
Grey Bear v. United States green
scotus · 2003
12004–2004
Sepulveda v. Alameida, Director, California Department of Corrections green
scotus · 2003
12004–2004
Beaton v. Crosby, Secretary, Florida Department of Corrections green
scotus · 2003
12004–2004
Taylor v. Florida green
scotus · 2004
12004–2004
Herrera v. Sublett neutral
scotus · 2004
12004–2004
Horn v. Banks green
scotus · 2002
12004–2004
Osterback v. Ingram green
scotus · 2002
12004–2004
Proffitt v. Florida green
scotus · 1976
12004–2004
Conahan v. State green
fla · 2003
12004–2004
Wright v. State green
fla · 2003
12004–2004
Marquard v. State green
fla · 2002
12004–2004
United States v. Walls green
dcd · 2002
12004–2004

Statutes the citing opinions construe

FL § 775.082 (15) FL § 775.084 (6) FL § 893.135 (5) FL § 921.141 (5) FL § 782.04 (4) FL § 784.07 (4) FL § 810.02 (4) FL § 316.1925 (3) FL § 775.021 (3) FL § 790.001 (3) FL § 856.015 (3) FL § 933.04 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 69 (1961–2025) FL 44 (1982–2024) AL 15 (1991–2018) NJ 11 (1979–2026) OH 9 (1988–2005) OK 7 (2007–2021) CO 7 (1990–2007) WA 7 (2006–2018) NC 6 (1987–1996) MD 4 (1990–2018) TX 2 (1992–1996) CT 2 (2001–2004) LA 2 (1998–2007) MS 2 (1993–1997) GA 2 (1997–1997)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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