Robert B. Leftwich, Petitioner v. Florida Department of Corrections, Respondent

Summary

The court held that the 1988 provisional-credit statute made an inmate ineligible for future provisional credits on any sentence once the inmate received a habitual-offender sentence, including a habitual-offender sentence imposed after an otherwise eligible sentence. Because this interpretation followed the statute's original plain meaning and did not apply the later amendment retroactively, the court found no ex post facto violation and approved the First District's decision while disapproving the contrary decision. Quince, J., dissenting, would have found the 1988 statute ambiguous, applied the rule of lenity, and held that retroactive exclusion of the credits violated the ex post facto clause.