State Department of Juvenile Justice v. S.M.
131 So. 3d 780
Fla.2013Background
- Juvenile S.M., on probation, was arrested for allegedly punching another minor and initially charged with aggravated battery; at detention hearing parties stipulated her RAI score was zero.
- Trial court placed S.M. on home detention with electronic monitoring after a dispute about whether a zero RAI score precluded home detention for an alleged probation violator.
- S.M. petitioned the Fourth District for a writ of habeas corpus seeking release; she did not attach her full RAI to the petition (only hearing transcripts and orders were attached).
- The Fourth District granted relief, holding that because S.M.’s RAI score was zero the trial court erred in placing her on home detention, without reviewing the actual RAI form.
- The State and Department of Juvenile Justice sought review, arguing the Fourth District erred by deciding habeas relief without the RAI and that a juvenile with a zero score may nonetheless be placed on home detention where the RAI’s admission criteria (e.g., alleged probation violation) authorize it.
- The Florida Supreme Court quashed the Fourth District, holding a district court may not grant habeas relief without the juvenile’s RAI in the record and that a juvenile with a zero RAI score may be placed on home detention when the RAI’s admission criteria (Section II, e.g., item J) or the statute authorize it.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| May a district court grant a juvenile’s pre-adjudicatory habeas petition without the juvenile’s RAI in the record? | S.M.: RAI irrelevant because parties stipulated to a zero score; habeas may be decided on the record provided. | State: Habeas requires an adequate record; RAI is essential under statute and must be included. | Court: Denial of adequate record; a district court may not grant habeas without the juvenile’s RAI in the record. |
| May a juvenile with a zero RAI score be placed on home detention when alleged to have violated probation? | S.M.: Zero score precludes placement in home detention; court erred. | State: RAI admission criteria (Section II, item J) and §985.255(1)(h) permit home detention for alleged probation violators regardless of total score. | Court: Juvenile may be placed on home detention with a zero score when the RAI’s admission criteria or statutory provisions authorize it. |
Key Cases Cited
- S.M. v. State, 91 So.3d 175 (Fla. 4th DCA 2012) (Fourth District decision granting habeas without reviewing RAI)
- R.J.L. v. State, 22 So.3d 130 (Fla. 5th DCA 2009) (permitting home detention for probation violator with zero RAI score)
- B.L.G. v. State, 928 So.2d 461 (Fla. 5th DCA 2006) (same)
- T.D.S. v. State, 922 So.2d 346 (Fla. 5th DCA 2006) (same)
- J.L.T. v. Department of Juvenile Justice, 104 So.3d 1257 (Fla. 2d DCA 2013) (certified conflict; held home detention proper for zero-score probation violators)
- Applegate v. Barnett Bank of Tallahassee, 377 So.2d 1150 (Fla. 1979) (appellate courts require an adequate record to review factual issues)
- G.L. v. State, 917 So.2d 342 (Fla. 5th DCA 2005) (habeas petition denied for inadequate record)