Matthew Dettle v. State of Florida

Summary

The court held that its rule requiring courts to determine multiple-conviction double-jeopardy claims from the charging document does not apply retroactively in postconviction proceedings to convictions that were final before the rule was announced. The court reached that conclusion under both Florida's retroactivity framework and the federal framework because the rule was procedural, did not expand the substantive double-jeopardy right, and did not justify disturbing final judgments. The court therefore answered the certified question in the negative and affirmed.