Brunson v. State

Defendant appeals her convictions for first-degree murder and possession of a firearm while engaged in a criminal offense. The instant offenses occurred on September 8, 1988, several months after the July 1, 1988 effective date of section 775.021(4), Florida Statutes (Supp.1988), the legislative amendment specifying the legislature’s intent that crimes with unique statutory elements be punished separately. In 1989, the supreme court reiterated that legislative intent stating: “[A]ll criminal offenses containing unique statutory elements shall be separately punished.” State v. Smith, 547 So.2d…