Javarris Lane v. State of Florida
151 So. 3d 20
| Fla. Dist. Ct. App. | 2014Background
- Lane, a juvenile offender at the time of the offenses, was sentenced after a Rule 3.800(b)(2) correction.
- The trial court resentenced Lane to life in prison without the possibility of parole for second-degree murder, with a concurrent 30-year sentence for aggravated child abuse, and a 50-year term for sexual battery consecutive to the life and 30-year terms.
- The First District Court of Appeal affirmed the life-without-parole sentence for murder but reversed the non-homicide sentences totaling 80 years.
- The court remanded for resentencing on the aggravated child abuse and sexual battery convictions.
- Florida law and Supreme Court precedent discussed include Miller v. Alabama, Graham v. Florida, and individualized mitigation requirements.
- The court analyzed whether the 80-year aggregate for non-homicide offenses constitutes a de facto life sentence and whether Graham’s protections apply to juveniles sentenced for non-homicide offenses.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether LJ’s LWOP murder sentence complies with Graham and Miller after individualized mitigation. | Lane argues Graham prohibits LWOP for juveniles absent meaningful review. | State contends a court may impose LWOP after considering youth and mitigating factors. | LWOP for murder upheld with individualized mitigation considerations. |
| Whether the aggregate 80-year non-homicide sentence constitutes a de facto life sentence under Graham. | Lane asserts the 80-year total deprives meaningful opportunity for release, violating Graham. | State argues statutory scheme and gain-time rules do not create a de facto life sentence. | Reversed and remanded for resentencing on non-homicide offenses to avoid de facto life. |
| Whether the non-homicide sentences should be resentenced separately when a homicide sentence remains in place. | Lane seeks resentencing on aggravated child abuse and sexual battery independently of the homicide. | State maintains the sentences are properly subject to Graham analysis in the aggregate. | Remanded for resentencing on the non-homicide convictions. |
Key Cases Cited
- Copeland v. State, 129 So. 3d 508 (Fla. 1st DCA 2014) (upholds life-without-parole after individualized mitigation in juvenile homicide case)
- Floyd v. State, 87 So. 3d 45 (Fla. 1st DCA 2012) (80-year non-homicide sentences functionally resemble life; Graham concerns remain)
- Graham v. Florida, 560 U.S. 48 (Supreme Court 2010) (juvenile sentencing requires meaningful opportunity for release; process-focused)
- Lawton v. State, 109 So. 3d 825 (Fla. 3d DCA 2013) (confirms Graham implications for juvenile nonhomicide offenses)
- Weiand v. State, 129 So. 3d 434 (Fla. 5th DCA 2013) (concurrent life sentences in related convictions; Graham considerations apply)