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Landrum v. State
Citations: 133 So. 3d 601; 2014 Fla. App. LEXIS 2795; 2014 WL 811580Docket: No. 2D13-3089
Court: District Court of Appeal of Florida; February 27, 2014; Florida; State Appellate Court
Laisha Landrum appeals the denial of her motion to correct an illegal sentence under Florida Rule of Criminal Procedure 3.800(a). In 2006, she was convicted of second-degree murder with a weapon and tampering with physical evidence, receiving a life sentence for the murder and five years for the tampering. Her conviction was affirmed on direct appeal. In her postconviction relief motion, Landrum argued that her life sentence was illegal based on the Supreme Court's decision in Miller v. Alabama, which deemed mandatory life sentences without parole unconstitutional for juveniles. The postconviction court denied her claim, stating that Miller does not retroactively apply, referencing Gonzalez v. State. However, the court later recognized that Miller does apply retroactively and certified conflict with Gonzalez in Toye v. State. As a result, the appellate court reversed the lower court's decision and remanded for proceedings consistent with Miller and Toye regarding Count I. Judges Silberman and Crenshaw concurred with the decision.