Kelly v. State

Lawrence Kelly appeals the dismissal of his motion to correct illegal sentence filed pursuant to Florida Rule of Criminal Procedure 3.800(a). Kelly was sentenced under the 1995 sentencing guidelines for an offense that allegedly occurred on July 21, 1996, within the relevant window to challenge such sentencing. See Smith v. State, 761 So.2d 419 (Fla. 2d DCA 2000). The trial court denied relief on the basis that this court in Heggs v. State, 718 So.2d 263 (Fla. 2d DCA 1998) declined to find that Chapter 95-184, Laws of Florida, violated the single subject rule. We reverse.

The supreme court has…