State of Florida v. Larry Phillips

Summary

The Court held that the circuit court lacked jurisdiction over the Jimmy Ryce Act commitment petition because Phillips's sentence had expired before the State initiated commitment proceedings. Under the Act, lawful custody must exist when the initial commitment steps are taken, and a sentence shortened by properly awarded credit or gain-time is no longer lawful custody after its recalculated expiration date. The Court also concluded that Phillips's more than six-year detention after sentence expiration without a trial seriously implicated due process. Justice Canady, dissenting, would have held that the Act permits proceedings based on actual custody and that no constitutional rule required dismissal.