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Owens v. State

Citations: 634 So. 2d 1160; 1994 Fla. App. LEXIS 4100; 1994 WL 148167Docket: No. 93-2347

Court: District Court of Appeal of Florida; April 27, 1994; Florida; State Appellate Court

Narrative Opinion Summary

In this case, the appellant, a 17-year-old, challenged the trial court’s imposition of adult sanctions following his no contest plea to charges of burglary and grand theft. The primary legal issue concerned the trial court's failure to issue a written order addressing the statutory criteria required under Florida Statutes Section 39.059(7)(c) when imposing adult sanctions. Despite sentencing the appellant to jail time and probation, the court did not provide the necessary written findings and conclusions, a requirement underscored by prior rulings in 'State v. Rhoden' and 'Troutman v. State'. Acknowledging this oversight, the State conceded the trial court's error. The appellate court, therefore, reversed the trial court's decision and remanded the case, instructing that a new sentencing hearing be conducted with a written order addressing the statutory criteria. Judges Miner and Allen concurred with the decision, emphasizing adherence to statutory mandates in the sentencing process.

Legal Issues Addressed

Appellate Court Authority in Remanding Cases

Application: The appellate court reversed the trial court’s order and remanded the case for resentencing in accordance with the statutory requirements.

Reasoning: The appellate court reversed the trial court’s order and remanded the case for resentencing in accordance with the law, instructing the trial court to issue a written order addressing all criteria for adult sanctions.

Imposition of Adult Sanctions under Florida Statutes Section 39.059(7)(c)

Application: The appellate court found that the trial court erred by imposing adult sanctions without a written order addressing statutory criteria.

Reasoning: Owens appealed the trial court's decision to impose adult sanctions without a written order addressing the statutory criteria required by section 39.059(7)(c) of the Florida Statutes.

Precedent and Statutory Compliance in Sentencing

Application: The appellate court relied on precedent requiring consideration of statutory criteria and individualized evaluation in sentencing decisions.

Reasoning: The State acknowledged the trial court's failure to follow the statutory requirements, which necessitate a consideration of each statutory criterion, an individualized evaluation, and written findings during sentencing, as established in State v. Rhoden and Troutman v. State.

Requirement for Written Findings in Sentencing

Application: The trial court's failure to provide a written order outlining mandatory findings and conclusions regarding adult sanctions necessitated reversal and remand.

Reasoning: However, there was no written order outlining the mandatory findings and conclusions regarding adult sanctions.