Kendall Young v. State
219 So. 3d 206
| Fla. Dist. Ct. App. | 2017Background
- Kendall Young, a juvenile, was adjudicated guilty of robbery with a firearm (first-degree felony) and received a ten-year mandatory minimum prison sentence under § 775.087(2).
- Young did not challenge the length of a ten-year sentence per se, but argued the mandatory minimum violated the Eighth Amendment under Miller and Graham because it prevented individualized sentencing consideration of youth.
- Young received a separate juvenile sentencing hearing under § 921.1401 where family members testified about his background, maturity, and rehabilitative prospects; the court imposed the lowest permissible sentence (ten years).
- Florida enacted juvenile sentencing statutes ( §§ 775.082, 921.1401, 921.1402 ) after Graham and Miller, creating review hearings for lengthy juvenile sentences (earliest review at 15 years for some offenses).
- Young also (for the first time on appeal) argued the 2014 juvenile sentencing statutes impliedly repealed the ten-year mandatory minimum; the State argued the issue was unpreserved and meritless.
- The Fifth District affirmed, holding the mandatory ten-year minimum did not violate the Eighth Amendment and rejecting the implied-repeal claim as unpreserved and, alternatively, lacking merit.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a ten-year mandatory minimum for a juvenile violates the Eighth Amendment under Miller/Graham | Young: Any mandatory minimum for juveniles violates Eighth Amendment because it forecloses individualized consideration of youth and diminished culpability | State: Juvenile received individualized sentencing hearing; statutes permit lengthy sentences but provide future review opportunities for certain long terms; legislature may set punishment ranges | Court: Affirmed — ten-year mandatory minimum does not violate Eighth Amendment where juvenile received individualized hearing and will be released young (meaningful opportunity for early release not required for such shorter terms) |
| Whether 2014 juvenile sentencing statutes impliedly repealed § 775.087(2)’s ten-year mandatory minimum | Young: Juvenile statutes supersede/repeal the mandatory minimum | State: Issue unpreserved; no clear legislative intent to repeal; presumption against implied repeal | Court: Issue unpreserved; even if considered, no clear intent to repeal and statutes construed to operate alongside § 775.087(2) — claim lacks merit |
Key Cases Cited
- Miller v. Alabama, 567 U.S. 460 (2012) (mandatory life without parole for juveniles who commit homicide violates the Eighth Amendment)
- Graham v. Florida, 560 U.S. 48 (2010) (life without parole for nonhomicide juvenile offenders violates the Eighth Amendment)
- Solem v. Helm, 463 U.S. 277 (1983) (courts should defer to legislative authority in setting punishment types and limits)
- Henry v. State, 175 So. 3d 675 (Fla. 2015) (Graham implicated when juvenile sentence lacks a review mechanism affording meaningful opportunity for early release)