On October 27, 2015, Petitioner appealed his conviction and sentence to Florida's Fourth District Court of Appeals [ECF No. 14 pp. 68-69]. The Fourth District affirmed on November 2, 2016, citing to the Fifth District's decision in Louzon and its own decision three years before in Taylor v. State, 114 So.3d 335 (Fla. Dist. Ct. App. 2013) [ECF No. 14 pp. 78, 139]. Sims v. State, 202 So.3d 954, 955 (Fla. Dist. Ct. App. 2016). Petitioner did not seek further review with the Florida Supreme Court.

The Fourth DCA affirmed Petitioner's conviction and sentence on November 2, 2016, citing Louzon, 78 So.3d at 678 and Taylor v. State, 114 So.3d 355 (Fla 4th DCA 2013), both of which held that previous release from a county jail qualified a defendant for PRR status under Florida law. See Sims v. State, 202 So.3d 954 (Fla. 4th DCA 2016).