Partlow v. State, 2013 Fla. App. LEXIS 78

Partlow, age 16 at the time of the crimes, was convicted of first-degree murder and robbery with a deadly weapon.
Trial court sentenced him to life without parole for murder and 45 years for robbery, consecutive.
Partlow challenged suppression of statements and physical evidence, arguing lack of reasonable suspicion for a detention.
Witnesses described a white Chevy Malibu with bondo matching a BOLO; police detained occupants after sighting near the crime scene.
Trial court denied suppression; on appeal, court affirmed the stop and Partlow’s convictions but vacated the murder sentence for resentencing.
Miller v. Alabama (2012) prompted reconsideration of mandatory life without parole for juveniles; the court remanded for resentencing and discussed options.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the stop/detention was supported by reasonable suspicion	Partlow	Partlow	The stop was reasonable; suppression denied.
Whether mandatory life without parole for a juvenile violates the Eighth Amendment	Partlow	State	Remand for resentencing required under Miller; life-with-parole-25 revival discussed.
What sentencing options are available post-Miller	Partlow	State	Remand and consideration of revival of life-with-parole-25; issue certified for further guidance.

Hunter v. State, 660 So.2d 244 (Fla. 1995) (defines 'founded suspicion' and factors for BOLO-based detentions)
State v. Setzler, 667 So.2d 343 (Fla. 1995) (construes Fourth Amendment per US Supreme Court guidance)
Coney v. State, 341 So.2d 238 (Fla. 3d DCA 1976) (reasonable investigatory stop with BOLO proximity and descriptions)
Miller v. Alabama, 132 S. Ct. 2455 (2012) (invalidated mandatory life without parole for juveniles)
Washington v. State, 103 So.3d 917 (Fla. 1st DCA 2012) (discussed post-Miller sentencing options and remand)
B.H. v. State, 645 So.2d 987 (Fla. 1994) (statutory revival doctrine and immediate predecessor limits)