Galan v. State

Galan appeals from a summary denial of his motion for relief filed pursuant to Florida Rule of Criminal Procedure 3.800(a). He sought to raise a Heggs v. State, 759 So.2d 620 (Fla.2000), claim that he was wrongfully sentenced under the unconstitutional 1995 amendments to the sentencing guidelines. The trial court denied his motion based on a window period commencing October 1, 1995 and closing September 30, 1996.1 However, the Florida Supreme Court has since determined the window period opened on October 1, 1995 and closed on May 24, 1997. See Trapp v. State, 760 So.2d 924 (Fla.2000). Galan’s…