Mr. Reeves was sentenced to prison for 20 years after being convicted of burglary, grand theft, resisting a law enforcement officer with violence and battery on a law enforcement officer. The judge determined that four separate criminal episodes occurred and sentenced Mr. Reeves to four consecutive five-year terms. The sentence for the resisting a law enforcement officer was based on the judge's classifying Mr. Reeves as a prison releasee reoffender. Mr. Reeves challenged the sentence. The Fifth District Court of Appeal upheld the sentence but found there were only two criminal episodes. It also said its decision conflicts with a holding by the 2nd DCA.