State of Florida v. Kenneth Purdy, 252 So. 3d 723

Kenneth Purdy (age 17 at offense) was convicted in 1997 of first‑degree murder (capital) and two first‑degree felonies (armed robbery and carjacking); originally sentenced to life without parole for murder and ~112.7 months consecutive for the other offenses.
After Miller v. Alabama, Purdy sought relief; the trial court resentenced the murder count to 40 years under chapter 2014‑220 and left the consecutive 112.7‑month terms unchanged.
Pursuant to the statutory review procedure (§ 921.1402), the trial court later found Purdy rehabilitated and reduced the murder sentence to time served plus probation; the court concluded it lacked statutory authority to modify the consecutive 112.7‑month terms.
The Fifth District held that at a juvenile sentence‑review hearing the trial court must review the offender’s aggregate sentence from the same sentencing proceeding and remanded for further review, certifying a question of great public importance.
The Florida Supreme Court accepted review to resolve whether the statutory scheme requires aggregation of sentences at a juvenile sentence‑review hearing and answered: no — the plain text limits review to the sentence(s) specified in chapter 2014‑220.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a juvenile sentence‑review hearing requires review of the offender’s aggregate sentence from the same sentencing proceeding	Purdy: trial court must consider and may modify the aggregate sentence for a single criminal episode when determining release based on demonstrated maturity and rehabilitation	State: statutory review is limited to the specific sentence(s) identified in chapter 2014‑220; no authority to alter other consecutive sentences	No. The court held the statute’s plain language authorizes review only of the sentence(s) specified by the statute, not aggregation of all consecutive sentences
Whether courts should judicially expand § 921.1402 to avoid Eighth Amendment problems from aggregate terms	Purdy: judicial construction required to preserve constitutionality and Miller/Graham principles for aggregate sentences arising from one episode	State: courts must apply unambiguous statutory text; legislative gaps do not authorize judicial expansion	The court refused to judicially expand the statute and declined to aggregate sentences at review; left open Eighth Amendment challenges in other forums

Graham v. Florida, 560 U.S. 48 (Eighth Amendment forbids life without parole for juvenile nonhomicide offenders; requires meaningful opportunity for release)
Miller v. Alabama, 567 U.S. 460 (Eighth Amendment forbids mandatory life without parole for juvenile homicide offenders)
Roper v. Simmons, 543 U.S. 551 (juveniles have diminished culpability)
Horsley v. State, 160 So.3d 393 (Fla. 2015) (Miller remedy: resentencing under chapter 2014‑220)
Falcon v. State, 162 So.3d 954 (Fla. 2015) (Miller applies retroactively)
Henry v. State, 175 So.3d 675 (Fla. 2015) (aggregate consecutive term‑of‑years sentences without review can violate Eighth Amendment)
Landrum v. State, 192 So.3d 459 (Fla. 2016) (proportionality concerns in juvenile sentencing)