Considering a Subsequent Crime As a Prior Violent Felony
In Elledge v. State, 346 So. 2d 998, 1001 (Fla. 1977), the Court determined it was proper to consider a subsequent crime as a prior violent felony.
There, the Court stated:
"It is clear that the Legislature referred to 'previous convictions' and not 'previous crimes.'" See also Knight v. State, 721 So. 2d 287 (Fla. 1998); Daugherty v. State, 419 So. 2d 1067, 1069 (Fla. 1982); King v. State, 390 So. 2d 315, 320 (Fla. 1980); Lucas v. State, 376 So. 2d 1149 (Fla. 1979).
Thus, because the conviction for the other violent felony occurred prior to this penalty phase, the trial court properly considered it as in aggravating factor.