Florida Department of Law Enforcement v. Angel Garcia
CourtDistrict Court of Appeal of Florida
Date FiledSeptember 2, 2026
Docket4D2025-2547
StatusPublished
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Full Opinion
DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA
FOURTH DISTRICT
FLORIDA DEPARTMENT OF LAW ENFORCEMENT,
Appellant,
v.
ANGEL GARCIA,
Appellee.
No. 4D2025-2547
[September 2, 2026]
Appeal from the Circuit Court for the Seventeenth Judicial Circuit,
Broward County; Frank David Ledee, Judge; L.T. Case No.
061991CF008523A88810.
Rose Garrison, Assistant General Counsel, Florida Department of Law
Enforcement, Tallahassee, and Jeffrey Paul DeSousa, Acting Solicitor
General, and Kevin A. Golembiewski, Senior Deputy Solicitor General,
Office of the Attorney General, Tallahassee, for appellant.
Ron M. Kleiner of Law Offices of Ron M. Kleiner, Miami, for appellee.
Robert Wayne Evans and James M. Orchard of Allen, Norton & Blue,
P.A., Tallahassee, for Amicus Curiae Florida Sheriffs Association on behalf
of appellant.
LEVINE, J.
The Florida Department of Law Enforcement (“FDLE”) appeals the
denial of its motion to vacate the trial court’s order directing FDLE to
remove Angel Garcia (“appellee”) from the sexual offender registry. We find
the following: (1) we have jurisdiction because proceedings concerning
removal from the sexual offender registry are civil in nature; (2) FDLE has
standing because the order directly affects its statutory duty to maintain
the sexual offender registry; and (3) appellee did not satisfy the statutory
requirements for removal under the version of section 943.0435 in effect
when he filed his petition in 2024. Thus, we reverse the trial court’s order
denying FDLE’s motion to vacate.
In 1991, appellee entered an open guilty plea to one count of sexual
battery with slight force, in violation of section 794.011(5), Florida
Statutes. Appellee was released from supervision in 2000.
In 1997, the legislature enacted section 943.0435, Florida Statutes,
which imposes registration requirements on sexual offenders. Ch. 97-299,
§ 8, Laws of Fla. Pursuant to the statute, FDLE is required to maintain
the sexual offender registry. In 1998, the legislature amended the statute
to permit offenders to petition for removal of the registration requirement
after being released from sanction for at least twenty years and not being
arrested for any crime since release. Ch. 98-81, § 7, Laws of Fla. The
legislature again amended the statute in 2007, increasing the release
requirement to twenty-five years and exempting certain offenses from
seeking relief. Among those crimes excluded from removal from the sexual
offender registry are convictions under section 794.011, which includes
the crime that appellee pled to. Ch. 07-209, § 2, Laws of Fla.
In 2021, appellee filed a petition, under section 943.0435(11), for
removal of the requirement to register as a sexual offender in Florida,
arguing he had been released from sanction for over twenty-one years.
Appellee claimed that the version of the statute in effect at the time he
completed his probation in 2000 was the applicable statute.
The state countered that the current version of the statute applied
because sexual offender registration obligations are procedural. According
to the state, appellee’s petition was premature because he had not been
released from supervision for at least twenty-five years. Further, and more
importantly, under the current law, appellee was exempt from the relief
requested because he was convicted of a disqualifying offense. The trial
court found the state’s arguments well-founded and denied the petition.
In July 2024, appellee filed a second petition for removal of the
requirement to register as a sexual offender. By then, appellee had been
released from sanction for twenty-four years. Appellee again argued that
the version of the statute in effect when he completed his sanctions in
2000 applied and that the 2007 amendment was not the applicable statute
and could not be applied retroactively.
The trial court, through a successor judge, granted the petition. The
trial court found that the 2007 amendment to section 943.0435 did not
apply retroactively. FDLE then moved to vacate the order pursuant to
section 943.0436(3), arguing that appellee was ineligible for removal from
the registry under the current applicable statute.
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Appellee responded that FDLE was a nonparty without standing to
contest the trial court’s order. Appellee argued that under section
943.0435(11), the state attorney—not FDLE—is the proper party to an
action for petition for removal from the requirements of sexual offender
registration. The trial court agreed with appellee and denied the motion,
stating: “FDLE does not have standing to challenge the removal of the
Defendant from [the] sexual offender registry pursuant to Florida Statute
§ 943.0436. That task is imposed on the State Attorney.” From this order,
FDLE appeals.
I. Jurisdiction
As an initial matter, we must first determine whether we have
jurisdiction to consider this appeal. Our jurisdiction turns on whether the
proceeding giving rise to the appealed order is civil or criminal in nature.
The appeal would not be authorized if criminal in nature because the order
appealed is not on the list of authorized appeals under Florida Rule of
Appellate Procedure 9.140, which governs appeals in criminal cases. See
Fla. R. App. P. 9.140(c).
However, if civil in nature, Florida Rule of Appellate Procedure 9.030,
which governs appeals in civil cases, provides for review of “final orders of
trial courts.” Fla. R. App. P. 9.030(b)(1)(A). A final order is one that ends
judicial labor in the cause. S.L.T. Warehouse Co. v. Webb, 304 So. 2d 97,
99 (Fla. 1974). We conclude, for reasons explained below, that the
proceedings giving rise to the appealed order are civil in nature, not
criminal. Thus, this court has jurisdiction to review the order denying
FDLE’s motion to vacate.
The version of section 943.0435 in effect when the petition was filed in
July 2024, states as follows:
(11) Except as provided in s. 943.04354, a sexual offender
shall maintain registration with the department for the
duration of his or her life . . . . However, a sexual offender
shall be considered for removal of the requirement to register
as a sexual offender only if the person:
(a) 1. Has been lawfully released from confinement,
supervision, or sanction, whichever is later, for at least 25
years and has not been arrested for any felony or
misdemeanor offense since release, provided that the
sexual offender’s requirement to register was not based upon
an adult conviction:
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....
b. For a violation of s. 794.011, excluding s. 794.011(10);
....
2. If the sexual offender meets the criteria in subparagraph 1.,
the sexual offender may, for the purpose of removing the
requirement for registration as a sexual offender, petition the
criminal division of the circuit court of the circuit . . . .
3. The court may grant or deny relief if the offender
demonstrates to the court that he or she has not been arrested
for any crime since release; the requested relief complies with
. . . federal standards applicable to the removal of registration
requirements for a sexual offender or required to be met as a
condition for the receipt of federal funds by the state; and the
court is otherwise satisfied that the offender is not a current
or potential threat to public safety. The state attorney in the
circuit in which the petition is filed must be given notice of the
petition at least 3 weeks before the hearing on the matter. The
state attorney may present evidence in opposition to the
requested relief or may otherwise demonstrate the reasons
why the petition should be denied. If the court denies the
petition, the court may set a future date at which the sexual
offender may again petition the court for relief, subject to the
standards for relief provided in this subsection.
4. The department shall remove an offender from classification
as a sexual offender for purposes of registration if the offender
provides to the department a certified copy of the court’s
written findings or order that indicates that the offender is no
longer required to comply with the requirements for
registration as a sexual offender.
....
(12) The Legislature finds that sexual offenders . . . often pose
a high risk of engaging in sexual offenses even after being
released from incarceration or commitment and that
protection of the public from sexual offenders is a paramount
government interest. Sexual offenders have a reduced
expectation of privacy because of the public’s interest in
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public safety and in the effective operation of government.
Releasing information concerning sexual offenders to law
enforcement agencies and to persons who request such
information, and the release of such information to the public
by a law enforcement agency or public agency, will further the
governmental interests of public safety. The designation of a
person as a sexual offender is not a sentence or a
punishment but is simply the status of the offender which is
the result of a conviction for having committed certain crimes.
§ 943.0435, Fla. Stat. (2024) (emphasis added).
Section 943.0435(11)(a)(2) permits a sexual offender to “petition the
criminal division of the circuit court” “for the purpose of removing the
requirement for registration as a sexual offender . . . .” We find that a
petition filed in the criminal division does not transform an otherwise civil
regulatory proceeding into a criminal proceeding. A petition under section
943.0435(11) does not challenge the criminal judgment or sentence.
Rather, it seeks relief from an ongoing statutory registration obligation
imposed by chapter 943.
The legislature has expressly stated that “[t]he designation of a person
as a sexual offender is not a sentence or a punishment but is simply the
status of the offender . . . .” § 943.0435(12), Fla. Stat. This is particularly
relevant here because appellee’s offense and sentencing predated the
enactment of Florida’s sexual offender registration requirements. Treating
the registration requirement as part of appellee’s punishment could
obviously raise ex post facto concerns.
The United States Supreme Court and Florida courts have clearly
rejected treating a later-enacted statutory requirement for sexual offender
registration as an additional punishment for an offense committed,
especially in the present case before the requirement even existed. For
example, in Smith v. Doe, the United States Supreme Court held that
sexual offender registration laws like Florida’s are “nonpunitive” “civil
regulatory scheme[s],” not systems for “impos[ing] punishment,” and
therefore do not violate the ex post facto clause. 538 U.S. 84, 92, 102,
105-06 (2003). Likewise, the Florida Supreme Court has stated: “The
registration requirement has absolutely no effect on the ‘range of the
defendant’s punishment’ for the crime,” and is therefore merely a
“collateral consequence” of a criminal conviction. State v. Partlow, 840 So.
2d 1040, 1043 (Fla. 2003). This court has similarly held that section
943.0435 is procedural and regulatory in nature, does not increase
punishment, and does not violate the ex post facto clause. Simmons v.
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State, 753 So. 2d 762, 763 (Fla. 4th DCA 2000); see also Freeland v. State,
832 So. 2d 923, 923 (Fla. 1st DCA 2002) (“The registration and reporting
requirements of Section 943.0435, Florida Statutes (2000) are regulatory
and procedural in nature and do not violate the ex post facto clause.”);
Givens v. State, 851 So. 2d 813, 814-15 (Fla. 2d DCA 2003). Registration
clearly is not a punishment. And this clearly is not a criminal proceeding.1
The reasoning in State v. Whitt, 96 So. 3d 1125 (Fla. 5th DCA 2012),
and State v. Brena, 278 So. 3d 850 (Fla. 3d DCA 2019), further supports
treating proceedings concerning the registration requirement as separate
and distinct from a criminal proceeding. In Whitt, the Fifth District held
that the trial court lacked postconviction jurisdiction to determine whether
a defendant was required to register because the registration requirement
was “unrelated to his sentence and was a collateral consequence of his
judgment and sentence.” 96 So. 3d at 1126. Similarly, in Brena, the Third
District held that the trial court lacked postconviction jurisdiction to
remove the statutory registration requirement because the designation
was not part of the defendant’s plea or sentence. 278 So. 3d at 854-55. 2
Appellee relies on State v. Korson, 413 So. 3d 207 (Fla. 2d DCA 2025),
review denied, No. SC2025-0970, 2026 WL 371524 (Fla. Feb. 10, 2026),
arguing that the supreme court’s denial of discretionary jurisdiction is
dispositive. However, the supreme court’s decision not to review Korson
“does not provide substantive guidance.” Heine v. Fla. Atl. Univ. Bd. of Trs.,
360 So. 3d 412, 419 (Fla. 4th DCA 2023). Further, decisions from other
districts are not binding on this court. State v. Hayes, 333 So. 2d 51, 53
1 The civil nature of sexual offender registration proceedings is further illustrated
by an analogy to Jimmy Ryce Act proceedings, which are also civil in nature. See
§ 394.910, Fla. Stat.; Osborne v. State, 907 So. 2d 505, 507 (Fla. 2005). Both
Jimmy Ryce and sexual registration requirements occur after completion of the
criminal sentence and are based on public safety concerns. See § 943.0435(12),
Fla. Stat. (stating that “protection of the public from sexual offenders is a
paramount government interest”); Westerheide v. State, 831 So. 2d 93, 104 (Fla.
2002) (recognizing “protection of the public” as a purpose for the Jimmy Ryce
Act).
2 Although Whitt and Brena both involved petitions for writ of certiorari, we note
that other cases have reviewed orders concerning removal from the sexual
offender registry by direct appeal. See State v. Marcel, 67 So. 3d 1223, 1224-25
(Fla. 3d DCA 2011) (reversing, on direct appeal, an order granting a petition for
removal under section 943.04354 after determining the defendant was statutorily
ineligible for relief); accord State v. Samuels, 76 So. 3d 1109 (Fla. 5th DCA 2011).
None of these cases discuss whether they could have proceeded, or did proceed,
as civil appeals.
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(Fla. 4th DCA 1976).
In Korson, the Second District concluded that an order granting
removal from the sexual offender registry was part of a criminal proceeding
and dismissed the state’s petition for writ of certiorari. 413 So. 3d at 208.
The court relied on King v. State, 911 So. 2d 229, 230 (Fla. 2d DCA 2005)
(en banc), which held that a postconviction challenge to a sexual predator
designation is not a separate civil order, but rather part of the criminal
proceeding. The court also relied on LaFave v. State, 149 So. 3d 662, 670
(Fla. 2014), which held that a “district court lack[s] jurisdiction to grant
the State’s petition for writ of certiorari where the trial court’s order is a
final order and where the State had no statutory right to appeal the order.”
We disagree with Korson’s jurisdictional analysis. Further, LaFave is
distinguishable because it involved the trial court’s early termination of
probation, which was clearly part of the defendant’s criminal sentence.
149 So. 3d at 664-65. In contrast, the present case concerns a statutory
registration requirement that was imposed independently from the
sentence. King is likewise distinguishable because it involved a sexual
predator designation that was expressly incorporated into the defendant’s
plea. 911 So. 2d at 231. Here, the registration requirement was not part
of appellee’s plea or sentence.
In summary, because these proceedings concern a statutory civil
regulatory requirement separate and apart from appellee’s criminal
sentence, FDLE’s appeal is authorized under rule 9.030(b)(1)(A). Thus, we
have jurisdiction to review the final order on appeal.
II. Standing
A. Standing in Trial Court
We next address whether FDLE has standing. FDLE argues that the
trial court erred in finding it lacked standing to challenge the order
directing appellee’s removal from the sexual offender registry. We agree.
Whether a party has standing presents a question of law reviewed de
novo. Johnson v. State, 78 So. 3d 1305, 1314 (Fla. 2012). Standing exists
when a party demonstrates that it reasonably expects to be affected by the
outcome of the proceedings. Id.
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Section 943.0436(3), Florida Statutes (2024), states:
If the court enters an order that affects an agency’s
performance of a duty imposed under the laws governing
sexual predators or sexual offenders, or that limits the
agency’s exercise of authority conferred under such laws, the
Legislature strongly encourages the affected agency to file
a motion in the court that entered such order. The
affected agency may, within 1 year after the receipt of any
such order, move to modify or set aside the order . . . .
(emphasis added).
We rely on section 943.0436(3), which expressly recognizes FDLE’s
authority to challenge an order affecting its statutory duties. FDLE is the
agency charged with maintaining Florida’s sexual offender registry. The
challenged order directly affected FDLE’s statutory duties to maintain the
sexual offender registry because the order required FDLE to remove
appellee from Florida’s sexual offender registry.
The trial court’s reliance on only section 943.0435(11) is misplaced. 3
Section 943.0435(11) addresses the state attorney’s participation in the
petition for removal. It does not address standing to challenge the
resulting order, nor does it preclude FDLE from seeking relief when an
order affects its statutory duties. The legislature’s authorization of the
state attorney’s ability to oppose a petition does not negate FDLE’s
independent duty to maintain the registry. Indeed, section 943.0436
expressly authorizes an affected agency to seek relief when an order
interferes with its duties. An order directing FDLE to remove a name from
the sexual offender registry would affect FDLE’s duties. Thus, FDLE has
the requisite standing to challenge the order.
B. Standing on Appeal
Appellee does not address FDLE’s standing in the trial court and
3 At the time appellee filed his July 2024 petition, section 943.0435(11) provided:
“The state attorney in the circuit in which the petition is filed must be given notice
of the petition at least 3 weeks before the hearing on the matter. The state
attorney may present evidence in opposition to the requested relief or may
otherwise demonstrate the reasons why the petition should be denied.” Section
943.0435 was amended effective October 1, 2024, see ch. 2024-73, § 2, Laws of
Fla., and now provides that both the state attorney and FDLE are entitled to
notice and to present evidence in opposition.
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instead claims only that FDLE does not have standing to appeal the denial
of the motion to vacate. We disagree. A nonparty may seek review on
appeal of an order that “directly adjudicates” its rights. Philip J. Padovano,
Florida Appellate Practice §§ 10:2-10:3 (2026 ed.). “[T]hose who are
aggrieved in some way by the order” may seek appellate review upon
“showing that the decision sought to be reviewed adversely affects some
legitimate interest of the party seeking relief . . . .” Id. at § 10:4; see also
Dep’t of Transp. v. Baird, 992 So. 2d 378, 381 n.4 (Fla. 5th DCA 2008)
(finding that a county expressway authority, a nonparty, had standing to
challenge an order expressly enjoining the authority); Mem’l Health Sys.,
Inc. v. Halifax Hospice, Inc., 689 So. 2d 373, 374 (Fla. 1st DCA 1997)
(finding a licensing agency—an adversely affected nonparty—had standing
to move to dissolve an injunction forbidding the agency from issuing a
license).
Here, FDLE was not simply an unrelated nonparty. As previously
discussed, section 943.0436(3) expressly authorizes FDLE to file a motion
challenging an order affecting its performance of a statutory duty. FDLE
exercised that statutory authority by timely filing a motion to vacate. The
denial of that motion left in place an order directing FDLE to remove
appellee from the registry. Accordingly, we find that FDLE has standing
to appeal the trial court’s denial of its motion to vacate.
III. Eligibility for Removal
Finally, our review turns to the merits of removing appellee from the
sexual offender registry. FDLE argues that appellee is not eligible for
removal from the sexual offender registry because section 943.0435 bars
removal for offenders convicted of sexual battery and, additionally, at the
time of the petition, appellee had not been released from sanction for at
least twenty-five years. We agree.
“The question of whether a statute applies retroactively or prospectively
is a pure question of law; thus, our standard of review is de novo.”
Bionetics Corp. v. Kenniasty, 69 So. 3d 943, 947 (Fla. 2011).
The threshold issue is which version of section 943.0435 applies to
appellee’s petition. Appellee contends the version in effect at the time his
supervision ended in 2000 applies, while FDLE asserts that the version in
effect when appellee filed his petition in 2024 applies. We agree with FDLE
and find that the trial court erred by applying the 2000 version of the
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statute. 4
In determining whether a statute applies retroactively, a court
considers (1) whether the statute itself expresses an intent that it apply
retroactively and (2) whether retroactive application is constitutional. Old
Port Cove Holdings, Inc. v. Old Port Cove Condo. Ass’n One, Inc., 986 So. 2d
1279, 1284 (Fla. 2008). The “general rule is that a substantive statute will
not operate retrospectively absent clear legislative intent to the contrary,
but that a procedural or remedial statute is to operate retrospectively.”
State Farm Mut. Auto. Ins. Co. v. Laforet, 658 So. 2d 55, 61 (Fla. 1995).
“[S]ubstantive law prescribes duties and rights” whereas procedural law
concerns itself with “the means and methods to apply and enforce those
duties and rights.” Alamo Rent-A-Car, Inc. v. Mancusi, 632 So. 2d 1352,
1358 (Fla. 1994).
Section 943.0435 does not express an intent that it apply retroactively.
Still, applying the version of the statute in effect when appellee filed his
petition is constitutionally permissible because section 943.0435 is
procedural rather than substantive. This court and other courts have
recognized that the registration and reporting requirements of section
943.0435 are “procedural in nature.” Simmons, 753 So. 2d at 763; see
also Freeland, 832 So. 2d at 923; Givens, 851 So. 2d at 814-15. Even
Korson acknowledged that “‘section 943.0435 is procedural in nature’ and
may properly be applied retroactively” and that “the current version of
section 943.0435” governs a petition for removal. 413 So. 3d at 209
(quoting Givens, 851 So. 2d at 814-15). Because section 943.0435 is
procedural, it may be applied retroactively so long as doing so does not
impair vested rights. Laforet, 658 So. 2d at 61.
No vested rights are implicated here. “A substantive vested right is an
immediate right of present enjoyment, or a present fixed right of future
enjoyment.” Clausell v. Hobart Corp., 515 So. 2d 1275, 1276 (Fla. 1987)
(citation omitted). “To be vested a right must be more than a mere
expectation based on an anticipation of the continuance of an existing law;
it must have become a title, legal or equitable, to the present or future
enforcement of a demand.” Id. (citation and emphasis omitted). A cause
4 FDLE also argues appellee would remain subject to the federal Sex Offender
Registration and Notification Act (“SORNA”), which generally requires lifetime
registration for certain tier III offenders. See 34 U.S.C. §§ 20911(4), 20915(a).
Because appellee is ineligible for removal under section 943.0435, Florida
Statutes (2024), we need not decide whether appellee’s Florida conviction would
qualify as a tier III offense under SORNA or what effect, if any, SORNA would
have on the relief sought in this proceeding.
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of action becomes a substantive vested right when it accrues. Williams v.
Am. Optical Corp., 985 So. 2d 23, 27 (Fla. 4th DCA 2008), aff’d sub nom.
Am. Optical Corp. v. Spiewak, 73 So. 3d 120 (Fla. 2011).
We find that appellee had no vested right to seek removal of the sexual
offender registration requirement when the legislature amended section
943.0435 in 2007. At the time of the amendment, appellee had not
satisfied the statutory prerequisites necessary to petition for removal of
the registration requirement because he had not been released from
sanction for twenty years. Thus, appellee had no accrued or vested right
to seek removal under the statute. Instead, he had only a mere expectation
based on an anticipation of the continuance of an existing law, which is
not a vested right. Clausell, 515 So. 2d at 1276.
Section 943.0435(11) establishes threshold eligibility requirements
that must be satisfied before a court may consider removing a registrant
from Florida’s sexual offender registry. Appellee did not satisfy the
statutory prerequisites for removal because he had not been released from
sanction for twenty-five years when he filed his petition. Moreover, and
more importantly, his conviction for sexual battery independently
rendered him ineligible for relief under the present statute.
Thus, because the current version of section 943.0435 governs
appellee’s 2024 petition, and appellee did not satisfy that statute’s
eligibility requirements, the trial court erred in granting his petition for
removal and in denying FDLE’s motion to vacate. We therefore reverse
and remand with instructions to grant FDLE’s motion to vacate and to
strike the trial court’s order removing appellee from the sexual offender
registry.
Reversed and remanded with instructions.
GROSS and FORST, JJ., concur.
* * *
Not final until disposition of timely-filed motion for rehearing.
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