Jose Martinez v. State of Florida

The defendant appeals an order denying his Rule 3.800(a) motion to correct an illegal sentence, in which he challenged a ten-year mandatory minimum sentence imposed under the 10-20-Life law. More than a decade after his conviction and sentence, he claims the mandatory minimum sentence was illegal.because the information failed to expressly allege he had “actual possession” of a firearm, thereby failing to provide him sufficient notice that the firearm enhancement would apply. We disagree and affirm.

The State charged the defendant with robbery while carrying a firearm. A jury convicted him as…