The Florida Supreme Court has determined that its 2018 decision, Lee v. State, does not extend double jeopardy protections retroactively in post-conviction cases.

“Today we consider a certified question of great public importance concerning the application of that rule: ‘Does the holding in [Lee] provide retroactive relief in postconviction proceedings pursuant to Fla. R. Crim. P. 3.850?… The answer is no: Lee does not apply retroactively to cases that were already final when it was decided.”

The October 24 ruling, Matthew Dettle v. State of Florida, Case No. SC2022-0417, involves a defendant who was convicted of three felonies — using a computer device to solicit a child, or a person believed to be a child, to engage in unlawful sexual conduct; traveling to meet a minor after such a solicitation; and use of a two-way communications device to facilitate or further the commission of a felony.