Michael Wilkes v. State of Florida

CourtDistrict Court of Appeal of Florida
DecidedNovember 19, 2025
Docket4D2025-2569
StatusPublished

This text of Michael Wilkes v. State of Florida (Michael Wilkes v. State of Florida) is published on Counsel Stack Legal Research, covering District Court of Appeal of Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Michael Wilkes v. State of Florida, (Fla. Ct. App. 2025).

Opinion

DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA FOURTH DISTRICT

MICHAEL WILKES, Appellant,

v.

STATE OF FLORIDA, Appellee.

No. 4D2025-2569

[November 19, 2025]

Appeal of order denying rule 3.800 motion from the Circuit Court for the Seventeenth Judicial Circuit, Broward County; Michael A. Usan, Judge; L.T. Case No. 11-740CF10A.

Michael Wilkes, Century, pro se.

No appearance required for appellee.

PER CURIAM.

Affirmed. See Maye v. State, 368 So. 3d 531, 532 (Fla. 6th DCA 2023), review granted, No. SC2023-1184, 2024 WL 1796831 (Fla. Apr. 25, 2024); Wainwright v. State, 411 So. 3d 392 (Fla. 2025) (holding that even if Erlinger v. United States, 602 U.S. 821 (2024), constitutes a change of law, it does not apply retroactively).

KUNTZ, C.J., GERBER and SHEPHERD, JJ., concur.

* * *

Not final until disposition of timely-filed motion for rehearing.

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Bluebook (online)
Michael Wilkes v. State of Florida, Counsel Stack Legal Research, https://law.counselstack.com/opinion/michael-wilkes-v-state-of-florida-fladistctapp-2025.