Supreme Court of Florida
Charles Paul v. State of Florida
April 11, 20132013 Fla. LEXIS 2885
Summary
The court held that shooting into an occupied vehicle under section 790.19 necessarily involves the use or threat of physical force or violence against an individual and therefore qualifies as a forcible felony under the prison releasee reoffender sentencing statute. It construed the statute as creating distinct offenses for buildings, vehicles, watercraft, and aircraft, rather than one conjunctive offense. The court approved the decision below, disapproved the conflicting decision, and concluded that the rule of lenity did not apply because the statute was not genuinely ambiguous.