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RECENT RELEASES - FLORIDA SUPREME COURT
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CRIMINAL LAW--DOUBLE JEOPARDY--RETROACTIVE APPLICATION OF LAW. The Court held that its decision in Lee v. State, 258 So. 3d 1297 (Fla. 2018), which "announced that a court must review only the charging document to determine whether multiple convictions violate a defendant's constitutional right against double jeopardy," did not apply retroactively to cases that were already final when Lee was decided. Additionally, the Court declined the State's invitation to recede from its decision in Witt v. State, 387 So. 2d 922 (Fla. 1980), and adopt the federal retroactivity test set forth in Teague v. Lane, 489 U.S. 288 (1989).
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