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Routine Enforcement Amended Final

Floyd v. State of Florida - Criminal Appeal Affirmed

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Summary

The Florida First District Court of Appeal affirmed Timothy Floyd's conviction and sentence. The appellate court rejected challenges to the trial court's failure to submit a PRR (prison releasee reoffender) determination to a jury, finding any error was harmless beyond a reasonable doubt. The HFO (Habitual Felony Offender) sentence was also affirmed.

What changed

The Florida First District Court of Appeal affirmed Timothy Floyd's conviction and sentence on April 8, 2026. The court rejected claims that the trial court erred by not submitting a prison releasee reoffender (PRR) determination to the jury, finding any error was harmless beyond a reasonable doubt. The habitual felony offender (HFO) sentence was also upheld.

This is a routine appellate affirmance that does not establish new precedent or create compliance obligations. The decision aligns with prior holdings in Hugger, McGlaun, Flowers, and Jett cases from the same district. Legal professionals monitoring Florida criminal sentencing practice may track this case as part of broader PRR/HFO jurisprudence.

What to do next

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Apr 8, 2026

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April 8, 2026 Get Citation Alerts Download PDF Add Note

Floyd v. State of Florida

District Court of Appeal of Florida

Disposition

Affirmed

Combined Opinion

FIRST DISTRICT COURT OF APPEAL
STATE OF FLORIDA


No. 1D2023-0558


TIMOTHY FLOYD,

Appellant,

v.

STATE OF FLORIDA,

Appellee.


On appeal from the Circuit Court for Leon County.
Stephen S. Everett, Judge.

April 8, 2026

PER CURIAM.

AFFIRMED. See Hugger v. State, 51 Fla. L. Weekly D169, D169,
--- So. 3d ---, 2026 WL 215872 (Fla. 1st DCA Jan. 28, 2026) (“[A]ny
error in not submitting the PRR determination to a jury was
harmless beyond a reasonable doubt.”); McGlaun v. State,
420 So. 3d 634, 636 (Fla. 1st DCA 2025) (“Since any error here is
harmless, Appellant’s HFO sentence is affirmed.”);
Flowers v. State, 424 So. 3d 1062, 1063 (Fla. 1st DCA 2025)
(affirming PRR sentence); Jett v. State, 426 So. 3d 596, 597 (Fla.
1st DCA 2025).

LEWIS, ROWE, and NORDBY, JJ., concur.


Not final until disposition of any timely and
authorized motion under Fla. R. App. P. 9.330 or
9.331.


Jessica J. Yeary, Public Defender, and Pamela D. Presnell,
Assistant Public Defender, Tallahassee, for Appellant.

James Uthmeier, Attorney General, and Kristie Regan, Assistant
Attorney General, Tallahassee, for Appellee.

2

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Last updated

Classification

Agency
FL DCA
Filed
April 8th, 2026
Instrument
Enforcement
Legal weight
Binding
Stage
Final
Change scope
Minor
Document ID
1D2023-0558
Docket
1D2023-0558

Who this affects

Applies to
Criminal defendants Legal professionals
Industry sector
9211 Government & Public Administration
Activity scope
Criminal appeals Sentencing
Geographic scope
Florida US-FL

Taxonomy

Primary area
Criminal Justice
Operational domain
Legal
Topics
Judicial Administration

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