Florida Parole Commission, Petitioner v. Joseph Robert Spaziano, Respondent

Summary

The court held that an inmate's mandamus challenge to the Florida Parole Commission's presumptive parole release date is a collateral criminal proceeding under section 57.085(10), Florida Statutes. Because an erroneous presumptive date can delay the effective and eventual parole release dates, the challenge is exempt from the statute's filing-fee and inmate-account lien requirements. Chief Justice Canady, dissenting, would have treated the proceeding as administrative rather than collateral to a criminal conviction or sentence and would have applied the lien requirements.