State of Florida v. Elizabeth Francis Marsh a/k/a Elizabeth Frances Marsh

Summary

The court held that separate convictions for DUI causing serious bodily injury and driving with a suspended license causing serious bodily injury do not violate double jeopardy. Applying the statutory same-elements test, the court concluded that each offense requires proof of an element the other does not and that none of the statutory exceptions applies. The court therefore quashed the Second District’s decision and approved the contrary district court decisions to the extent consistent with its ruling.