STATE OF FLORIDA v. FRANKLIN JONES
230 So. 3d 22
| Fla. Dist. Ct. App. | 2017Background
- Franklin Jones, an inmate, was disciplined under the Broward Sheriff’s Office Inmate Handbook for assault/fighting and received 30 days disciplinary detention; no good-time was actually forfeited.
- The handbook’s code of conduct authorizes sanctions including disciplinary segregation, room restriction, and loss of earned gain time.
- The State subsequently charged Jones with battery on a law enforcement officer based on the same conduct.
- Jones moved to dismiss the criminal information on double jeopardy grounds, arguing the disciplinary scheme imposed criminal punishment (specifically potential loss of gain time).
- The trial court granted dismissal, finding potential revocation of gain time was punitive and thus barred prosecution; the State appealed.
- The Fourth District reversed, applying Hudson’s two-step test and related precedent to conclude prison disciplinary sanctions are remedial and do not bar subsequent criminal prosecution.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether institutional disciplinary sanctions (including potential loss of gain time) constitute "criminal punishment" for double jeopardy purposes | Jones: Handbook sanctions are punitive; potential loss of gain time is criminal punishment, so prosecution is barred | State: Disciplinary sanctions are remedial/administrative to maintain order and do not preclude criminal prosecution | Held: Reversed dismissal — disciplinary sanctions are remedial, not criminal, so double jeopardy does not bar prosecution |
Key Cases Cited
- Hudson v. United States, 522 U.S. 93 (establishes two-step test for determining whether civil sanctions are punitive for double jeopardy)
- Mayes v. United States, 158 F.3d 1215 (11th Cir. 1998) (prison disciplinary sanctions are remedial and do not bar subsequent criminal prosecution)
- Kennedy v. Mendoza-Martinez, 372 U.S. 144 (provides multi-factor test to distinguish civil from criminal sanctions)
- Breed v. Jones, 421 U.S. 519 (double jeopardy protects against successive criminal prosecutions)
- United States v. Ursery, 518 U.S. 267 (discusses civil forfeiture and punitive effect analysis)
- Helvering v. Mitchell, 303 U.S. 391 (distinguishes criminal punishment from other sanctions)