The Florida District Court of Appeal has upheld a ruling in the case of Thomas Crews v. State of Florida, case number 6D2025-1085. This decision, made on September 18, 2026, is significant for those involved in legal disputes regarding sentencing errors related to Apprendi claims. The ruling clarifies how such claims should be raised and who is affected by this legal interpretation.
In this case, Thomas Crews, the appellant, challenged a previous ruling made by the Circuit Court for Collier County. The dispute centers around the interpretation of legal procedures concerning sentencing errors, particularly those related to the Apprendi decision, which established that any fact that increases a criminal sentence beyond the statutory maximum must be submitted to a jury. This case reached the District Court of Appeal after Crews sought to appeal the lower court's decision.
The legal arguments in this case revolved around the application of Florida Rule of Appellate Procedure 9.141(b)(2). Crews contended that his appeal should be considered under this rule, which allows certain claims to be raised after a conviction. However, the court's ruling indicates that the specific type of claim he raised is not appropriate under this rule.
The court ruled that the claim made by Crews was not valid under the established legal framework. The opinion stated, "[R]ule 3.800(a) is not the proper vehicle for raising a claim of error under Apprendi and its progeny, including Alleyne (‘Apprendi claims’)." This ruling effectively clarifies that individuals cannot use this rule to challenge their sentences based on Apprendi-related claims. The judges on the panel, Nardella, Smith, and Brownlee, concurred with this decision.
This ruling is significant as it aligns with a previous decision made in May 2026 in the case of Maye v. State, which also addressed the handling of Apprendi claims. The court's decision to recede from the earlier case of Plott v. State, which had allowed for such claims under rule 3.800(a), sets a new precedent for how these legal arguments will be treated in Florida courts.
The impact of this ruling extends beyond just Thomas Crews. It affects anyone in Florida who may have similar claims related to sentencing errors based on the Apprendi decision. By establishing that these claims cannot be raised under the specific rule mentioned, the court has limited the avenues available for defendants seeking to challenge their sentences on these grounds.
Going forward, this ruling may discourage some defendants from pursuing Apprendi claims in Florida, as they will need to explore other legal avenues to raise such issues. The clarification provided by this ruling could lead to a more uniform approach in handling these types of claims in the state's courts.
As for what’s next, it is unclear if Thomas Crews will seek further legal remedies or if there are any related cases pending that might address similar issues. The court's ruling is not final until the time expires for filing a motion for rehearing, which means there could be further developments in this case.