Eustache v. State, 199 So. 3d 484

In 2006 Eustache pleaded to robbery with a firearm (an offense carrying a ten‑year minimum‑mandatory) but was sentenced as a youthful offender to 4 years prison + 2 years probation.
He committed new drug crimes, admitted a substantive probation violation, and his probation was revoked; the trial court later sentenced him to 15 years with a 10‑year minimum‑mandatory.
Eustache filed two Florida Rule of Criminal Procedure 3.850 motions: first led to plea withdrawal; after re‑pleading he challenged his sentence as involuntary/illegal and counsel as ineffective for misadvice about minimum‑mandatory exposure.
The legal question was whether, upon revocation of youthful offender supervision for a substantive violation, a trial court that elects to sentence above the youthful‑offender cap must impose any minimum‑mandatory sentence that would have applied originally.
The district court recognized intra‑district and inter‑district conflict (notably Blacker and Goldwire) and framed the statutory interpretation of sections 958.14 and 948.06 as granting trial courts two options upon revocation: continue under the youthful‑offender cap or impose any sentence that could originally have been imposed (including minimum‑mandatories).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a court that revokes youthful‑offender supervision and elects to sentence above the youthful‑offender cap is required to impose minimum‑mandatory penalties that would have applied at original sentencing	Eustache: Such minimum‑mandatory sentences are inapplicable to youthful offenders even after revocation (relying on Blacker/Christian/Arnette interpretations)	State: Once court exercises discretion to impose sentence above cap, it must impose applicable minimum‑mandatory sentences (consistent with Goldwire as read by State)	Court: Trial courts have discretion to impose either a cap sentence or any sentence that could originally have been imposed; if the court chooses the latter and the original sentencing exposure included a minimum‑mandatory, that minimum must be imposed.
Whether Eustache is entitled to relief because counsel misadvised him about mandatory exposure	Eustache: Counsel’s incorrect advice made plea involuntary and ineffective assistance	State: Even if advice was incorrect, the court ultimately imposed a lawful sentence greater than the minimum, so no relief warranted	Court: No relief — sentence lawful because once court chose to impose sentence above the cap it properly imposed the ten‑year minimum mandatory.

Blacker v. State, 49 So.3d 785 (Fla. 4th DCA 2010) (held minimum‑mandatory penalties do not apply where youthful‑offender status remained in effect after revocation)
Goldwire v. State, 73 So.3d 844 (Fla. 4th DCA 2011) (held trial court has discretion to sentence as youthful offender or impose non‑youthful‑offender sentence after substantive violation)
Christian v. State, 84 So.3d 437 (Fla. 5th DCA 2012) (discussed confusion over “youthful offender status” and questioned Goldwire’s statement on mandatory sentences)
Yegge v. State, 186 So.3d 563 (Fla. 2d DCA 2015) (concluded legislature intended loss of youthful‑offender sentencing limits after substantive violation and agreed trial court may impose minimum‑mandatory; certified conflict with Blacker)
State v. Arnette, 604 So.2d 482 (Fla. 1992) (interpreted Youthful Offender Act regarding sentencing cap; relied upon in some districts to limit post‑revocation enhancements)
Mendez v. State, 835 So.2d 348 (Fla. 4th DCA 2003) (noted minimum‑mandatory sentences do not apply to an initial youthful‑offender sentence)