Christopher Allen Pryor v. State of Florida

Summary

The court held that Pryor’s prior conviction for escaping from a juvenile detention facility qualifies as one of the predicate offenses required to establish violent career criminal status. Because the juvenile-escape statute expressly incorporates the adult escape statute, the provisions must be read together, making the conviction a valid predicate for the firearm-possession offense. The court therefore approved the district court’s judgment affirming Pryor’s conviction without addressing the preservation and fundamental-error question.