96 So. 3d 1080
Fla. Dist. Ct. App.2012Background
- S.L., a 13-year-old, was accused of interfering with the administration or functions of an educational institution and resisting arrest without violence at Renick Educational Center on Sept. 22, 2010.
- S.L. shouted insults and obscene gestures toward Officer Dadd in a hallway near the cafeteria as Dean Jefferson and Dadd attempted to manage the situation.
- S.L. was escorted to a private area, then returned to the cafeteria; after further outbursts he was taken to an office and handcuffed by officers.
- S.L. escalated conduct en route to transportation, kicked and pulled away from officers, and was eventually Baker Acted for welfare.
- At a November 1, 2010 trial, S.L. was adjudicated guilty of interfering with a school’s administration (reversed on that count) and resisting arrest without violence (upheld).
- The trial court’s disposition included probation violations for four other cases and commitment to a moderate-risk facility.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the evidence supports interference with a school’s administration | S.L.’s conduct disrupted normal school functions. | No material disruption; no intent to impede functions. | Interference conviction reversed; no material disruption shown. |
| Whether the evidence supports resisting arrest without violence | S.L. obstructed officers while enforcing custody. | Officers lawfully detained him; actions amounted to resisting. | Resisting arrest conviction affirmed. |
Key Cases Cited
- M.C. v. State, 695 So.2d 477 (Fla. 3d DCA 1997) (establishes framework: culpable intent and material disruption of school function)
- A.M.P. v. State, 927 So.2d 97 (Fla. 5th DCA 2006) (conduct to stop or impede normal school function prohibited)
- T.J. v. State, 867 So.2d 1238 (Fla. 5th DCA 2004) (continued disruptive behavior disrupts normalized school function)
- M.M. v. State, 997 So.2d 472 (Fla. 5th DCA 2008) (intent is a question for fact-finder; conduct may violate if intended to disrupt)
- S.W.W. v. State, 833 So.2d 877 (Fla. 3d DCA 2003) (reversal where no evidence of disruption or intent)
- L.T. v. State, 941 So.2d 551 (Fla. 2d DCA 2006) (reversal where no disruption or intent to disrupt normal function)
- J.J. v. State, 944 So.2d 518 (Fla. 4th DCA 2006) (upholds conviction where conduct disrupts school functions)
- T.T. v. State, 865 So.2d 674 (Fla. 4th DCA 2004) (conviction affirmed for disruption of school after administrator interference)