Justia Juvenile Law Opinion Summaries

Articles Posted in Florida Supreme Court
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The Supreme Court quashed the decision of the Fourth District Court of Appeal in this juvenile sentencing case remanding for the trial judge to remedy a harmful Alleyne error through a "ministerial correction" of sentence for which the defendant "need not be present," holding that the remedy fell short of the de novo sentencing required by Williams v. State, 242 So. 3d 280 (Fla. 2018).At issue was the proper remedy for a harmful Alleyne error that occurs where, in sentencing a juvenile offender under Fla. Stat. 775.082(1)(b), the trial court enhances the sentence without a jury finding of the fact that authorizes the enhancement. In this case, Defendant, who committed two homicides, argued that he should be resentenced because the jury was not asked to find, and did not find, that he "actually killed, attempted to kill, or intended to kill the victims," as required under section 775.082(1)(b)1. The Fourth District concluded that the trial court committed a harmful Alleyne error in resentencing Defendant and remanded for "ministerial correction" of Defendant's sentences, for which Defendant "need not be present[.]" The Supreme Court quashed the Fourth District's decision, holding that Defendant was entitled to the de novo resentencing required by Williams. View "Puzio v. State" on Justia Law

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The Supreme Court quashed the Second District Court of Appeal's decision holding, in pertinent part, that the trial court erred in failing to notify J.A.R. of his asserted right to a hearing to challenge the $100 public defender fee imposed at sentencing, holding that the Second District erred in striking the public defender's fee.The trial court adjudicated J.A.R. delinquent for committing two felonies and a misdemeanor. In addition, the court imposed a $100 public defender fee under Fla. Stat. 938.29 without apprising J.A.R. of the fee or informing him of the right to a hearing to contest the fee. The Second District struck the fee on the grounds that the trial court did not give J.A.R. notice of his right to a hearing to contest the fee. The Supreme Court quashed the decision below, holding that since the $100 public defender fee was the statutory minimum under section 938.29(1)(a), the trial court was not required to provide notice and hearing as to that fee. View "State v. J.A.R." on Justia Law

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The Supreme Court approved the court of appeal's decision to uphold Defendant's sentence and disapproved of several recent court decisions to the extent they held that resentencing is required for all juvenile offenders serving a sentence longer than twenty years without the opportunity for early release based on demonstrated maturity and rehabilitation, holding that Defendant in this case did not establish a violation of Miller v. Alabama, 567 U.S. 460 (2012).Defendant was charged with the first-degree murder of her mother committed when she was age seventeen. Defendant pled guilty to second-degree murder in exchange for a forty-year sentence. Defendant later challenged her sentence as cruel and unusual punishment under Miller. The trial court denied Defendant's petition. The court of appeal affirmed but certified conflict with several decisions of other district courts. The Supreme Court affirmed, holding that because Defendant did not establish that her sentence was a life sentence or the functional equivalent of a life sentence Defendant failed to establish that her sentence violated the Eighth Amendment, Miller, or its equivalent on a juvenile homicide offender whose youth has not been taken into account at sentencing. View "Pedroza v. State" on Justia Law

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The Supreme Court held that juvenile offenders’ sentences of life with the possibility of parole after twenty-five years do not violate the Eighth Amendment of the United States Constitution, as delineated by the United States Supreme Court in Graham v. Florida, 460 U.S. 48 (2010), Miller v. Alabama, 467 U.S. 460 (2012), and related cases, and therefore, such juvenile offenders are not entitled to resentencing under Fla. Stat. 921.1402.Appellee was convicted of first-degree premeditated murder and related crimes he committed when he was sixteen years old. Appellee was sentenced to life imprisonment with the possibility of parole after twenty-five years for the murder. Appellee later filed a motion for postconviction relief asserting that he was entitled to relief under Miller. The trial court summarily denied the motion, determining that Miller was inapplicable because Appellee had the opportunity for release on parole. The Fourth District Court of Appeal reversed, concluding that resentencing was required. The Supreme Court quashed the Fourth District’s opinion, holding that juvenile offenders’ sentences of life with the possibility of parole after twenty-five years do no violate Graham’s requirement that juvenile have a meaningful opportunity to receive parole. View "State v. Michel" on Justia Law

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At issue was whether, when a juvenile offender is entitled to a sentence review hearing, the trial court is required to review the aggregate sentence that the juvenile is serving from the same sentencing proceeding in determining whether to modify the juvenile’s sentence based upon demonstrated maturity and rehabilitation.The Fifth District Court of Appeal held a trial court is required to review a juvenile offender’s aggregate sentence at a statutorily required sentence review hearing in order to determine whether the modify the overall sentence based on maturity and rehabilitation. The Supreme Court quashed the Fifth District’s decision, holding that the plain language of the juvenile sentencing statutes does not provide for aggregation of sentences at judicial sentence review. View "State v. Purdy" on Justia Law

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Juvenile offenders’ sentences of life with the possibility of parole after twenty-five years do not violate the Eighth Amendment of the United States Constitution as set forth in Graham v. Florida, 560 U.S. 48 (2010), Miller v. Alabama, 567 U.S. 460 (2012), and Virginia v. LeBlanc, 137 S. Ct. 1726 (2017), and therefore, such juvenile offenders are not entitled to resentencing under Fla. Stat. 921.1402.Defendant was convicted of first-degree premeditated murder and armed robbery, crimes he committed when he was sixteen years old. Defendant was sentenced to life imprisonment with the possibility of parole after twenty-five years for the murder conviction. Defendant later filed a motion for postconviction relief pursuant to Fla. R. Crim. P. 3.850, asserting that he was entitled to relief under Miller. The trial court denied the motion, concluding that Miller was inapplicable because Defendant had the opportunity for release on parole. The court of appeal reversed, concluding that Atwell v. State, 197 So. 3d 1040 (Fla. 2016), required resentencing even where the offender may later obtain parole. The Supreme Court quashed the decision below, holding that juvenile offenders’ sentences of life with the possibility of parole after twenty-five years under Florida’s parole system do not violate Graham, and therefore, such offenders are not entitled to resentencing. View "State v. Michel" on Justia Law

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Upon revocation of a youthful offender’s probation for a substantive violation, the trial court is authorized to either impose another youthful offender sentence, with no minimum mandatory, or to impose an adult Criminal Punishment Code sentence requiring imposition of any minimum mandatory term of incarceration associated with the offense of conviction.Defendant was eighteen years old when he pleaded guilty to robbery with a firearm, which carried a ten-year minimum mandatory sentence. The trial court sentenced Defendant as a youthful offender under the Florida Youthful Offender Act to four years in prison and two years of probation. After Defendant violated his probation the trial court revoked his probation and sentenced him on the underlying offense of robbery with a firearm to fifteen years in prison, with a ten-year minimum mandatory sentence. The court of appeal affirmed. The Supreme Court quashed the decision below and remanded the case for resentencing, holding that where a defendant is initially sentenced to probation or community control as a youthful offender and the trial court later revokes supervision for a substantive violation and imposes a sentence above the youthful offender cap under Fla. Stat. 958.14 and 948.06(2), the court is required to impose a minimum mandatory sentence that would have originally applied to the offense. View "Eustache v. State" on Justia Law

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Defendant, a juvenile nonhomicide offender, was entitled to resentencing under Graham v. Florida, 560 U.S. 48 (2010), because the sentencing court did not make the required findings at Defendant’s sentencing hearing to comport with chapter 2014-220, Laws of Florida, and because Defendant’s sentence lacked any review mechanism.Defendant was convicted of one count of attempted felony murder and one count of attempted armed robbery for a crime he convicted when he was fifteen years old. Defendant was sentenced as an adult to thirty years’ imprisonment for the attempted felony murder and fifteen years’ imprisonment for the attempted armed robbery, to be served concurrently. Defendant’s sentence did not provide for judicial review. The Supreme Court ordered that Defendant be resentenced under the juvenile sentencing provisions in chapter 2014-220. View "Morris v. State" on Justia Law

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Defendant pleaded guilty to two counts of armed sexual battery, armed burglary, and armed robbery. Defendant was fifteen years old at the time he committed the offenses. The trial court sentenced Defendant to two life sentences and two concurrent twenty-five-year terms. After Graham v. Florida was decided, the trial court resentenced Defendant to concurrent sentences of forty-five years. On appeal, the First District Court of Appeal concluded that Defendant was not entitled to resentencing under Henry v. State, which applied the new sentence review statute to a Graham-eligible defendant, because Defendant’s forty-five-year term of imprisonment did not constitute a de facto life sentence in violation of Graham. However, the district court certified a question to the Supreme Court regarding the need for clarity on a category of Graham cases. The Supreme Court disapproved the court of appeal’s decision affirming Defendant’s resentencing, holding that a defendant whose initial sentence for a nonhomicide crime violated Graham and who was resentenced to concurrent forty-five year terms was entitled to new resentencing under the framework established in chapter 2014-220, Laws of Florida. View "Kelsey v. State" on Justia Law

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In 2004, when Petitioner was sixteen years old, she and her boyfriend committed murder. Petitioner was convicted of second-degree murder with a weapon, which was classified as a life felony. The trial court sentenced Petitioner to life without parole without indicating what findings of aggravating or mitigating circumstances warranted imposition of the life-without-parole sentence as opposed to a term-of-years sentence under the sentencing guidelines then in place. After the United States Supreme Court decided Miller v. Alabama, Petitioner filed a motion for postconviction relief in the form of resentencing. The circuit court denied the motion. The Second District Court of Appeal affirmed, concluding that because Petitioner was sentenced under a discretionary sentencing scheme, Miller was inapplicable to Petitioner’s life-without-parole sentence. The Supreme Court quashed the Second District’s decision, holding that Miller applies to juvenile offenders whose sentences of life imprisonment without parole were imposed pursuant to a discretionary sentencing scheme when the sentencing court, in exercising that discretion, did not take into account the individualized sentencing considerations of a juvenile offender’s youth. View "Landrum v. State" on Justia Law