What did the court decide?

The court affirmed the trial court’s denial of resentencing for Patrick Maxwell, finding no error in applying the Florida Supreme Court’s Pedroza standard.

Who is affected by this decision?

Patrick Maxwell, the defendant seeking resentencing, is directly affected; the decision also guides other cases where resentencing for juvenile offenders is sought under Pedroza.

Why was resentencing denied?

Because the Florida Supreme Court’s Pedroza decision limits resentencing to juvenile offenders sentenced to life or a functional equivalent, and Maxwell’s sentence did not meet that standard.

Can this decision be appealed?

Further appeal to the Florida Supreme Court may be possible if jurisdictional criteria are met, but the opinion does not address whether such an appeal will be pursued.

Patrick Maxwell v. State of Florida

Docket 6D2025-0756

Court of record · Indexed in NoticeRegistry archive · AI-enriched for research

Criminal AppealAffirmed

Filed: Apr 24, 2026 · 1 week ago
Jurisdiction: Florida
Court: District Court of Appeal of Florida
Type: Opinion
Case type: Criminal Appeal
Disposition: Affirmed
Docket: 6D2025-0756

Appeal from the circuit court's denial of a defendant's request for resentencing following a remand from the Fifth District

Summary

The Sixth District Court of Appeal affirmed the trial court’s denial of Patrick Maxwell’s request for resentencing. Maxwell sought resentencing under an earlier Fifth District decision, but before resentencing occurred the Florida Supreme Court clarified in Pedroza v. State that juvenile offenders need resentencing only if their sentence is life or a functional equivalent. The appellate court held the trial court correctly applied the new Pedroza standard and therefore properly denied resentencing. The court found no error and affirmed the lower court’s order.

Issues Decided

Whether the trial court erred in denying resentencing for a juvenile offender after an intervening Florida Supreme Court decision
Whether Pedroza v. State requires resentencing for this defendant given his sentence is not life or its functional equivalent

Court's Reasoning

The court concluded the Florida Supreme Court’s decision in Pedroza changed the governing law after the Fifth District’s mandate, limiting resentencing relief to cases where the sentence is life or a functional equivalent. Because Maxwell’s sentence did not meet that threshold, the trial court correctly followed the intervening higher-court precedent rather than the earlier appellate mandate. That change in controlling law justified denying resentencing.

Authorities Cited

Pedroza v. State291 So. 3d 541 (Fla. 2020)
Maxwell v. State241 So. 3d 277 (Fla. 5th DCA 2018)
McKinney v. Graham414 So. 3d 286 (Fla. 6th DCA 2025)
Gilchrist v. State299 So. 3d 620 (Fla. 5th DCA 2020)

Parties

Appellant: Patrick Maxwell
Appellee: State of Florida
Judge: Michael J. Snure
Attorney: Blair Allen, Public Defender
Attorney: Susan M. Shanahan, Assistant Public Defender
Attorney: James Uthmeier, Attorney General
Attorney: Rebecca Rock McGuigan, Assistant Attorney General

Key Dates

Decision date: 2026-04-24

What You Should Do Next

1
Consult appellate counsel
If Maxwell seeks further review, he should consult counsel promptly to evaluate merits and possible jurisdictional grounds for discretionary review to the Florida Supreme Court.
2
Consider motion for rehearing
File a motion for rehearing in the Sixth District within the applicable deadline if there are grounds to challenge the panel’s legal conclusions or overlooked authority.
3
Assess sentence status
Confirm the current sentence and any scheduled review hearings to determine whether future relief might be available under evolving law or different factual predicates.

Frequently Asked Questions

What did the court decide?: The court affirmed the trial court’s denial of resentencing for Patrick Maxwell, finding no error in applying the Florida Supreme Court’s Pedroza standard.
Who is affected by this decision?: Patrick Maxwell, the defendant seeking resentencing, is directly affected; the decision also guides other cases where resentencing for juvenile offenders is sought under Pedroza.
Why was resentencing denied?: Because the Florida Supreme Court’s Pedroza decision limits resentencing to juvenile offenders sentenced to life or a functional equivalent, and Maxwell’s sentence did not meet that standard.
Can this decision be appealed?: Further appeal to the Florida Supreme Court may be possible if jurisdictional criteria are met, but the opinion does not address whether such an appeal will be pursued.

The above suggestions and answers are AI-generated for informational purposes only. They may contain errors. NoticeRegistry assumes no responsibility for their accuracy. Consult a qualified attorney before relying on them.

Full Filing Text

SIXTH DISTRICT COURT OF APPEAL
STATE OF FLORIDA
_____________________________

Case No. 6D2025-0756
Lower Tribunal No. 2009-CF-013807
_____________________________

PATRICK MAXWELL,

Appellant,

STATE OF FLORIDA,

Appellee.
_____________________________

Appeal from the Circuit Court for Orange County.
Michael J. Snure, Judge.

April 24, 2026

PER CURIAM.

This court finds no error and affirms the lower court’s denial of Appellant’s

request for resentencing. Although the Fifth District reversed and remanded for a

full resentencing hearing in Maxwell v. State, 241 So. 3d 277, 278 (Fla. 5th DCA

2018), before the resentencing hearing could be conducted, the Florida Supreme

Court issued Pedroza v. State, 291 So. 3d 541 (Fla. 2020), holding that resentencing

for juvenile offenders is not required unless a sentence is for life or a functional
equivalent.1 291 So. 3d at 549 (“We uphold Pedroza’s sentence because she has not

established that it is a life sentence or the functional equivalent of a life sentence.”);

see also Gilchrist v. State, 299 So. 3d 620, 621 (Fla. 5th DCA 2020) (affirming “the

trial court’s order amending the sentences to provide for a review hearing and

denying resentencing.” (emphasis added)). As such, the trial court was correct to

comply with the new legal standard.

AFFIRMED.

NARDELLA, SMITH and KAMOUTSAS, JJ., concur.

Blair Allen, Public Defender, and Susan M. Shanahan, Assistant Public Defender,
Bartow, for Appellant.

James Uthmeier, Attorney General, Tallahassee, and Rebecca Rock McGuigan,
Assistant Attorney General, Daytona Beach, for Appellee.

NOT FINAL UNTIL TIME EXPIRES TO FILE MOTION FOR REHEARING
AND DISPOSITION THEREOF IF FILED

1
Generally, “[a] mandate communicates the appellate court’s judgment to the
lower court and directs the lower court’s action.” McKinney v. Graham, 414 So. 3d
286, 290 (Fla. 6th DCA 2025). However, “[t]here are limited exceptions to this
broad and important rule. One exception is when an intervening decision by a higher
court supersedes the legal basis of the appellate court’s mandate before the trial
court’s judicial labor is complete. The trial court may then disregard the mandate to
comply with the new legal standards.” Id.