Jermaine C. Jackson v. State of Florida, 191 So. 3d 423

Jermaine Jackson was convicted of robbery with a firearm while wearing a mask and sentenced to life; he was 20 at the offense but 21 at sentencing.
If sentenced under Florida's Youthful Offender Act, Jackson would have faced a six-year cap.
In 2008 the Legislature amended section 958.04(1)(b) to make youthful-offender eligibility depend on being younger than 21 at sentencing (previously it depended on age at offense).
Jackson moved under Fla. R. Crim. P. 3.800(b)(2) alleging disparate sentencing, improper costs, and that §958.04(1)(b) violated equal protection and due process; the motion was deemed denied and he appealed.
The Fourth District affirmed most rulings, reversed certain costs, and held §958.04(1)(b) constitutional; the Florida Supreme Court granted review on the statutory-constitutionality question.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether §958.04(1)(b) violates equal protection by classifying eligibility based on age at sentencing	Jackson: classification is arbitrary; no other Florida statute uses age-at-sentencing and it triggers strict scrutiny	State: youthful-offender status is discretionary, not a fundamental right or suspect class; rational-basis review applies and the statute furthers legitimate objectives	Court: Upheld statute under rational-basis; no equal protection violation
Whether §958.04(1)(b) violates substantive due process by affecting liberty interests and chilling trial rights	Jackson: tying eligibility to sentencing age penalizes exercise of the right to trial and may coerce guilty pleas	State: eligibility is legislative, serves rehabilitation and anti-association goals, and need only satisfy rational relation to legitimate state interest	Court: No substantive due process violation; statute reasonably furthers legitimate objectives

Crist v. Ervin, 56 So.3d 745 (Fla. 2010) (constitutional challenges reviewed de novo)
State v. Lick, 390 So.2d 52 (Fla. 1980) (statutes presumed constitutional; challenger bears burden)
Miller v. State, 971 So.2d 951 (Fla. 5th DCA 2007) (rational-basis test applies where no fundamental right or suspect class)
Gregory v. Ashcroft, 501 U.S. 452 (U.S. 1991) (age is not a suspect classification)
Palko v. Connecticut, 302 U.S. 319 (U.S. 1937) (framework for identifying fundamental rights under substantive due process)
Reno v. Flores, 507 U.S. 292 (U.S. 1993) (requirement to carefully define asserted substantive-due-process rights)