J.L.T. v. Department of Juvenile Justice
104 So. 3d 1257
Fla. Dist. Ct. App.2013Background
- Six juveniles petitioned for writ of habeas corpus seeking release from home detention pending adjudicatory hearings.
- All juveniles were on probation or conditional release and allegedly violated curfew, leading to separate custody pickups in early June 2012.
- DJJ prepared RAIs at intake and, despite zero-point scores, recommended home detention for each juvenile.
- Detention hearings resulted in continued home detention with electronic monitoring for 21 days pending adjudication.
- Petitioners argued that a score of six or fewer points on the RAI mandates release and that section 985.255(l)(h) does not permit home detention without a qualifying score.
- The trial court denied habeas relief; the court of appeals certified conflict with S.M. and T.K.B. and upheld detention under subsection 985.255(l)(h).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether zero-point RAI juveniles may be detained for probation violations. | Petitioners (S.M. line) argue no detention without a qualifying RAI score. | State argues detention may continue if probation violations justify home detention under the RAI framework. | Detention upheld; conflict certified. |
| Whether the RAI's Admission Criteria permit detention irrespective of total points. | RAI requires qualifying score for detention under S.M./T.K.B. logic. | Admission Criteria allow detention when JPV/conditional release conditions are violated. | RAI allows detention despite zero points under J (violation of probation). |
| Whether section 985.255(1) requires a qualifying RAI score to continue detention. | Detention can only be continued with a qualifying RAI score. | Statute authorizes continued detention during intake if detention is supported by RAI assessment. | Detention permissible; continued detention under 985.255(l)(h) proper. |
Key Cases Cited
- S.M. v. State, Department of Juvenile Justice, 91 So.3d 175 (Fla. 4th DCA 2012) (RAI-based detention exceptions precede score reasoning)
- T.K.B. v. Durham, 63 So.3d 60 (Fla. 1st DCA 2011) (RAI scoring thresholds govern detention eligibility)