St. Cyr v. State
106 So. 3d 487
| Fla. Dist. Ct. App. | 2013Background
- St. Cyr's Florida Rule of Criminal Procedure 3.800(a) motion to correct illegal sentence was denied.
- St. Cyr argues the trial court erred by not evaluating his mental health status before sentencing.
- The court remanded regarding whether the youthful offender status should have been maintained after revocation of community control, due to missing records.
- The revocation was based on substantive violations, allowing a youthful offender sentence up to the statutory maximum, not restricted by a six-year cap for technical violations.
- St. Cyr contends the six-year cap on youthful offender sentences is exceeded by his fifteen-year term; the opinion clarifies the cap applies only to technical violations.
- The absence of sentencing records prevents a clear determination whether St. Cyr was sentenced as a youthful offender after revocation; the court remands with directions to sentence accordingly or attach records.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Mental health evaluation | St. Cyr | State | Not proper under 3.800(a) motion |
| Revocation effect on youthful offender status | St. Cyr | State | Remanded for proper sentencing or record attachment |
| Six-year cap applicability | St. Cyr | State | Fifteen-year term permissible up to statutory maximum after substantive violation |
| Need for sentencing records | St. Cyr | State | Remand to determine if sentenced as youthful offender or attach records |
Key Cases Cited
- Potter v. State, 769 So.2d 519 (Fla. 3d DCA 2000) (3.800(a) improper use; not proper vehicle for claim)
- Rogers v. State, 972 So.2d 1017 (Fla. 4th DCA 2008) (confusion about six-year cap clarified)
- Boynton v. State, 896 So.2d 898 (Fla. 3d DCA 2005) (six-year cap context)
- Christian v. State, 84 So.3d 437 (Fla. 5th DCA 2012) (clarifies six-year cap handling)
- Flores v. State, 46 So.3d 102 (Fla. 3d DCA 2010) (six-year cap interpretation)
- Lee v. State, 67 So.3d 1199 (Fla. 2d DCA 2011) (revocation substantive violations; not limited to six years)
- Blacker v. State, 49 So.3d 785 (Fla. 4th DCA 2010) (status must be continued; deficient revocation can be raised on 3.800(a))