Jacques v. State, 95 So. 3d 419

Jacques pleaded guilty to trafficking in cocaine and was sentenced as a youthful offender to six years’ probation.
An affidavit alleged probation violations including serious crimes; a hearing found substantive violations and probation was revoked.
Jacques was then sentenced to 30 years in prison after revocation.
Jacques filed a postconviction motion under Florida Rule of Criminal Procedure 3.800 claiming the youthful offender status was not continued and challenging the six-year limit for a non-substantive violation.
The trial court denied relief; the appellate court reverses in part and remands for correction to reflect continued youthful offender status while preserving the substantive sentence.
The court holds the substantive sentence was authorized, but the youthful offender status must be continued on resentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether youthful offender status was continued on resentencing after a probation violation.	Jacques: status should be continued.	State: continued status not clearly reflected in order.	Remanded to correct sentencing order to reflect continued youthful offender status.
Whether the 30-year sentence for a substantive probation violation was permissible.	Jacques: not beyond maximum for the offense.	State: substantive violation allows maximum sentence for the offense.	Authorized under § 958.14 and related statutes.

Lee v. State, 67 So.3d 1199 (Fla. 2d DCA 2011) (continual youthful offender status required on resentencing after violation)
Flores v. State, 46 So.3d 102 (Fla. 3d DCA 2010) (substantive violation can occur even if new charges are nolle prossed)
Morency v. State, 955 So.2d 67 (Fla. 3d DCA 2007) (new offenses can constitute probation violations even if dismissed)
Yegge v. State, 88 So.3d 1058 (Fla. 2d DCA 2012) (youthful offender benefits and continued designation impact)
Blacker v. State, 49 So.3d 785 (Fla. 4th DCA 2010) (supporting principle on continuing youthful offender status)