Narrative Opinion Summary
The case involves a juvenile, referred to as J.L.B., who was adjudicated delinquent for two counts of battery and one count of committing a lewd act upon a child. The court upheld the adjudication for the battery offenses, acknowledging these charges were properly applied. However, the court reversed the adjudication for the lewd act charge due to the incorrect application of an updated statute. The statute, revised after the offense, classified the act as a second-degree felony, whereas the statute in effect at the time classified it as a third-degree felony. Consequently, the court mandated a remand for new disposition orders that align with the correct statutory classification, emphasizing the necessity for individual disposition orders for each charge as per Juvenile Rule of Procedure 8.115(c). Additionally, the court identified an error in the original commitment order, which lacked a required brief statement of facts, underscoring the legal requirement for written findings of fact in disposition orders post-January 1, 2001. The adjudication was thus partially affirmed, partially reversed, and remanded for compliance with procedural standards.
Legal Issues Addressed
Adjudication of Juvenile Delinquencysubscribe to see similar legal issues
Application: The juvenile, J.L.B., was adjudicated delinquent for two counts of battery, which were affirmed by the court.
Reasoning: The court affirms the adjudication for the battery offenses.
Application of Statutory Amendments in Juvenile Casessubscribe to see similar legal issues
Application: The court reversed the adjudication for a lewd act due to an incorrect application of a revised statute that was not applicable at the time of the offense.
Reasoning: The appeal involves J.L.B., a juvenile adjudicated delinquent...reverses the lewd act adjudication due to reliance on an inapplicable statute.
Procedural Requirements for Juvenile Disposition Orderssubscribe to see similar legal issues
Application: Each offense committed by a juvenile requires a separate disposition order, and the case was remanded for orders consistent with Juvenile Rule of Procedure 8.115(c).
Reasoning: As a result, the court reverses the adjudication for the lewd act and remands the case for new disposition orders consistent with the correct statutory classification, following the directive that each case requires a separate disposition order per Juvenile Rule of Procedure 8.115(c).
Requirement for Correct Statutory Classificationsubscribe to see similar legal issues
Application: The court mandates correction of the adjudication based on the statute effective at the time of the offense, which classified the lewd act as a third-degree felony, not a second-degree felony.
Reasoning: Specifically, J.L.B. was charged under a revision of Florida Statutes that classified the lewd act as a second-degree felony, whereas the applicable statute at the time classified it as a third-degree felony.
Requirement of Written Findings in Disposition Orderssubscribe to see similar legal issues
Application: The court highlighted the need for written findings of fact in disposition orders, effective January 1, 2001, correcting the original order's lack of a brief statement of facts.
Reasoning: The ruling does not address whether the statement needed to be written or could be oral, but emphasizes that effective January 1, 2001, the law mandates written findings of fact in disposition orders.