Demetrius C. Cooper v. State
235 So. 3d 1034
Fla. Dist. Ct. App.2018Background
- In 2009 Cooper was convicted of aggravated battery (second-degree felony) and originally sentenced under the Youthful Offender Act (YOA) to 479 days DOC, 18 months community control, then 18 months probation.
- After revocation of community control for a substantive violation, the trial court imposed a 20-year minimum-mandatory DOC term under the 10-20-Life statute.
- Cooper’s judgment and sentence were affirmed on direct appeal, and his sentence was later amended to retain youthful-offender classification.
- Cooper filed a Florida Rule of Criminal Procedure 3.800(a) “Motion to Correct Illegal Sentence,” arguing the imposed minimum-mandatory term was illegal because it exceeded the statutory maximum for a second-degree felony.
- The Fifth District reversed the trial court’s denial, holding that under the YOA and related statutes a court may exceed the YOA cap on revocation but may not impose a minimum-mandatory term that would not have applied to the original youthful-offender sentence.
Issues
| Issue | Cooper's Argument | State's Argument | Held |
|---|---|---|---|
| Whether a trial court may impose a minimum-mandatory sentence after revoking community control for a youthful offender when that minimum exceeds the YOA maximum | Minimum-mandatory term is illegal because it exceeds the statutory maximum for the second-degree felony and conflicts with YOA limits | Defendant argued trial court may impose any sentence permissible under section 948.06 after revocation, including minimum-mandatory terms applicable to the underlying offense | Court held the YOA’s sentencing limitations follow the youthful offender; revocation can lead to a sentence above the YOA cap but a minimum-mandatory term that would not have applied originally may not be imposed |
Key Cases Cited
- Christian v. State, 84 So. 3d 437 (Fla. 5th DCA 2012) (YOA sentencing features carry forward on revocation; minimum-mandatory applicability analyzed)
- Eustache v. State, 199 So. 3d 484 (Fla. 4th DCA 2016) (conflicting decision certifying question regarding minimum-mandatory terms after youthful-offender revocation)
- Cooper v. State, 56 So. 3d 783 (Fla. 5th DCA 2011) (direct appeal affirming conviction and sentence)
- Hill v. State, 692 So. 2d 277 (Fla. 5th DCA 1997) (YOA defendant may receive sentence above 6-year cap after substantive violation)
- Kelly v. State, 739 So. 2d 1164 (Fla. 5th DCA 1999) (minimum-mandatory term could not be imposed on youthful offender)
- Carter v. State, 786 So. 2d 1173 (Fla. 2001) (definition of illegal sentence and Rule 3.800(a) purpose)
- Blakley v. State, 746 So. 2d 1182 (Fla. 4th DCA 1999) (definition of illegal sentence used in Carter)