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Bennett v. State

Citation: 229 So. 3d 1289Docket: CASE NO. 1D16-5467

Court: District Court of Appeal of Florida; November 29, 2017; Florida; State Appellate Court

Narrative Opinion Summary

Michael Anthony Bennett appeals his convictions for dealing in stolen property and grand theft. The court finds merit in Bennett's argument that his dual convictions violate section 812.025, Florida Statutes (2015), which prohibits such dual convictions when the offenses arise from a single scheme. The State concurs with this assessment. Citing precedents, the court emphasizes that both offenses occurred as part of one ongoing scheme, thus constituting double jeopardy. Consequently, the court affirms the conviction for dealing in stolen property but reverses the conviction for grand theft. Judges Lewis, Kelsey, and M.K. Thomas concur in the decision.

Legal Issues Addressed

Double Jeopardy in Single Scheme Offenses

Application: The court determines that both offenses were part of one ongoing scheme, which constitutes double jeopardy, and therefore reverses the conviction for grand theft while affirming the conviction for dealing in stolen property.

Reasoning: Citing precedents, the court emphasizes that both offenses occurred as part of one ongoing scheme, thus constituting double jeopardy.

Prohibition of Dual Convictions under Florida Statutes Section 812.025

Application: The court applies this statute to find that Bennett's dual convictions for dealing in stolen property and grand theft, arising from a single scheme, violate the statute's prohibition against dual convictions.

Reasoning: The court finds merit in Bennett's argument that his dual convictions violate section 812.025, Florida Statutes (2015), which prohibits such dual convictions when the offenses arise from a single scheme.