Young v. State
110 So. 3d 931
Fla. Dist. Ct. App.2013Background
- Young was 14–15 during four armed robberies in 2000 and originally received concurrent life-without-parole sentences.
- After Graham v. Florida, the postconviction court granted a 3.800(a) motion and scheduled resentencing.
- At resentencing, Young urged a meaningful opportunity to obtain release based on maturity and rehabilitation; the State presented crime-victims evidence.
- The resentencing court sentenced Young to 30 years in prison followed by 10 years’ probation, finding rehabilitation but emphasizing punishment for the crimes.
- Young appeals arguing Graham required consideration of rehabilitation at resentencing; the State argues Graham’s scope does not demand it here.
- The court affirms, holding Graham does not require a rehabilitation-based mechanism at resentencing for nonlifewithout-parole juvenile nonhomicide offenders; the 30-year sentence complies.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does Graham require a resentencing court to consider rehabilitation at resentencing? | Young argues Graham mandates a meaningful opportunity tied to rehabilitation at resentencing. | Young reading misreads Graham; it prohibits life without parole without opportunity, not a blanket requirement at resentencing. | No; Graham does not require rehabilitation-based consideration at resentencing for this case. |
| Did the resentencing court comply with Graham by avoiding a life sentence and providing a term with release potential? | Young contends Graham requires ongoing opportunity to release based on maturity. | Court ensured release opportunity exists via a nonlife sentence to be released after term. | Yes; the 30-year sentence with later release complies with Graham. |
| Is Miller v. Alabama applicable to Young's case? | Young relies on Miller to argue tailored consideration. | Miller is inapplicable to a nonhomicide juvenile offender not serving life without parole. | No; Miller does not apply here. |
| Was the resentencing record sufficient to show consideration of rehabilitation and maturity? | Young asserts the court ignored rehabilitation evidence. | Record shows consideration of offenses, youth, rehabilitation evidence, and statutory factors. | Yes; record demonstrates consideration of rehabilitation and maturity. |
Key Cases Cited
- Graham v. Florida, 559 U.S. 44 (U.S. 2010) (prohibits life-without-parole for juvenile nonhomicide offenders without meaningful opportunity for release)
- Miller v. Alabama, 132 S. Ct. 2455 (U.S. 2012) (distinguishes homicide from nonhomicide juveniles; not applicable to nonhomicide offenders)
- Nusspickel v. State, 966 So.2d 441 (Fla. 2d DCA 2007) (trial court discretion in sentencing within statutory limits)
- Walle v. State, 99 So.3d 967 (Fla. 2d DCA 2012) (upholds long juvenile-nonhomicide sentences not violating Graham)