Williams v. State

Over 29 years after being sentenced as an habitual felony offender, and after at least five motions for post-conviction relief, appellant filed a motion for relief under Florida Rule of Criminal Procedure 8.800(a) saying that his sentence was “illegal” under the rule because there were not sufficient predicate felonies to habitualize him. There is no time limit to the filing of rule 3.800(a) motions.

In Bover v. State, 797 So.2d 1246, 1247 (Fla.2001), the Florida Supreme Court expanded rule 3.800(a) to apply to situations where “the requisite predicate felonies essential to qualify a defendant…