Mr. McDonald was convicted of carjacking with a firearm and robbery with a firearm. He was sentenced concurrently to life in prison under a sentencing law that enhances punishment for "prison releasee re-offenders" and to a 10-year sentence under the 10-20-Life law, which enhances punishment for people who are armed when they commit serious crimes. The Fourth District Court of Appeal upheld the sentences, and receded from its prior decisions holding that sentences under the "prison releasee re-offenders" statute and the 10-20-Life law cannot be imposed concurrently unless the sentence under the 10-20-Life law is greater. The Fourth District certified conflict with decisions of the Second District, and Mr. McDonald sought this review