Chauncey Davis v. State, 223 So. 3d 1106

At 17, Chauncey Davis pleaded nolo contendere to multiple violent felonies; the trial court designated him a youthful offender and imposed 1 year community control followed by 4 years 10 months probation.
While on community control, after turning 18, Davis committed an armed carjacking and committed technical violations; the court revoked community control and probation and sentenced him to an aggregate 45 years' imprisonment.
Davis argued he was entitled to be sentenced under Florida’s juvenile offender sentencing statutes (sections 775.082, 921.1401, 921.1402) because the original offenses were committed when he was a minor.
The trial court declined to apply juvenile sentencing; the Fifth District reviewed whether juvenile-sentencing protections apply when the new sentence follows a probation violation committed after the defendant turned 18.
The court followed Justice Pariente’s concurrence in Guzman v. State and held that because Davis violated community control after turning 18, juvenile sentencing statutes did not apply; the aggregate sentence was affirmed.
The court also found error in the trial court’s failure to retain Davis’s youthful offender status on resentencing, but Davis failed to preserve that claim; the opinion affirms without prejudice to later postconviction relief on that point.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether juvenile-offender sentencing statutes apply when original offense occurred as a minor but probation/community-control violation occurs after turning 18	Davis: juvenile sentencing applies because the underlying offenses were committed when he was a minor	State: juvenile sentencing does not apply because the violation and revocation occurred after Davis turned 18	Held: Juvenile statutes do not apply; sentence affirmed (adopting Justice Pariente’s Guzman analysis)
Whether youthful-offender status must continue after revocation and resentencing	Davis: youthful-offender designation should have been continued on resentencing	State: (implicit) trial court acted within discretion at sentencing	Held: Trial court erred by not continuing youthful-offender status, but Davis forfeited review by not preserving or timely moving; relief denied without prejudice to postconviction challenge

Guzman v. State, 183 So. 3d 1025 (Fla. 2016) (discussing juvenile-sentencing relief limits when probation violation occurs after age 18; Pariente, J. concurrence adopted)
Graham v. Florida, 560 U.S. 48 (2010) (juvenile nonhomicide offenders cannot be sentenced to life without meaningful opportunity for release)
Miller v. Alabama, 567 U.S. 460 (2012) (mandatory life without parole for juveniles unconstitutional)
Henry v. State, 175 So. 3d 675 (Fla. 2015) (Florida Supreme Court addressing Graham’s application)
Gridine v. State, 175 So. 3d 672 (Fla. 2015) (Florida Supreme Court addressing Graham’s application)
Long v. State, 99 So. 3d 997 (Fla. 5th DCA 2012) (once youthful-offender sentence is imposed, status must be continued upon resentencing)