Yegge v. State, 186 So. 3d 553

In 2003 Yegge pleaded guilty to armed burglary (allegation he was armed), manufacture of marijuana, and possession of paraphernalia; the court withheld adjudication and sentenced him as a youthful offender to probation for the felony charges.
After repeated probation violations, in 2005 Yegge admitted a substantive violation (possession of a controlled substance and introducing contraband into a detention facility); the court revoked probation, adjudicated guilt, revoked youthful-offender designation, and imposed a 10-year mandatory minimum for armed burglary plus five years for manufacture.
Yegge filed a Florida Rule of Criminal Procedure 3.800(a) motion challenging the postconviction sentence; this court earlier reversed the denial of relief and remanded to reinstate youthful-offender classification but expressly upheld the 10-year mandatory minimum in that prior opinion.
On remand the trial court resentenced Yegge as a youthful offender but left the ten-year mandatory minimum intact; Yegge appealed, arguing mandatory minimum enhancements cannot apply to youthful-offender sentences.
The Second District majority held that section 958.14 subjects youthful offenders who commit substantive violations to sentencing under section 948.06, which permits imposition of the original maximum sentence (including applicable enhancements); thus the 10-year mandatory minimum is lawful.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether mandatory-minimum sentencing enhancements (10/20/Life under §775.087) may be imposed after a youthful offender commits a substantive violation of probation	Yegge: mandatory minimums and other youthful-offender sentencing limits continue to apply; enhancements cannot be imposed on a resentencing that preserves youthful-offender status	State: §958.14 exposes youthful offenders who commit substantive violations to §948.06, allowing imposition of any sentence the court could originally have imposed, including statutory enhancements	The court held enhancements may be imposed after a substantive violation; the 10-year mandatory minimum was lawful and affirmed

Yegge v. State, 88 So.3d 1058 (Fla. 2d DCA 2012) (prior panel ruling keeping youthful-offender status but upholding ten-year mandatory minimum)
State v. Arnette, 604 So.2d 482 (Fla. 1992) (Florida Supreme Court interpreted pre-1985/1985-era §958.14 to limit resentencing of youthful offenders to a six-year cap)
Mendenhall v. State, 48 So.3d 740 (Fla. 2010) (statutory enhancement may be treated as part of the defendant’s sentencing exposure and trial court has discretion to impose mandatory minimum within statutory scheme)
Lareau v. State, 573 So.2d 813 (Fla. 1991) (reclassification penalties can affect maximum guideline exposure)
Goldwire v. State, 73 So.3d 844 (Fla. 4th DCA 2011) (trial court has discretion to impose a non-youthful-offender sentence after a substantive violation; enhancements may be applied when discretion results in non-youthful sentencing)
Blacker v. State, 49 So.3d 785 (Fla. 4th DCA 2010) (contrary view: mandatory minimums cannot be imposed on youthful offenders after substantive violation)
Wooten v. State, 782 So.2d 408 (Fla. 2d DCA 2001) (held 10/20/Life enhancements do not apply to original youthful-offender sentences)