Young v. State (2010)

In Young v. State, 37 So. 3d 389 (Fla. 5th DCA 2010), the Fifth District rejected Young's claim on appeal "that the trial court erred in imposing consecutive prison releasee reoffender (PRR) sentences on his five aggravated assault convictions because all of the crimes occurred during the course of a single criminal episode." Young, 37 So. 3d at 389. The Fifth District adopted the trial court's reasoning that: "Based upon the Supreme Court's decision in Reeves, the cases cited by defendant, all of which rely upon Hale v. State, 630 So. 2d 521 (Fla. 1993), as their foundational authority, are called into question. Given the holding in Reeves and the stated intent of the PRR statute to punish eligible offenders to the fullest extent of the law, the court can find no reasonable interpretation of the PRR statute that would prohibit consecutive PRR sentences but permit the imposition of consecutive PRR and criminal punishment code sentences as approved in Reeves." Id. at 391.