JAMES SATALINO, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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Florida appellate court reversed a juvenile's adult sentence because the trial court failed to make individualized findings of suitability as required by statute, using only a form checklist instead.
A trial court must make specific individualized findings in a written order to impose adult sanctions on a juvenile; a form checklist is insufficient.
[1] A trial court imposing adult sanctions on a juvenile must make specific individualized findings in a written order rather than relying on a form checklist to comply with…
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Join FLexlaw to unlock all legal intelligence“the trial court failed to make the required individualized findings concerning the suitability of adult sanctions for him. The form order is insufficient to satisfy the prescriptions of section 39.059(7)(c)”
Court's explanation of why the sentence must be reversed
James Satalino, age fourteen, was charged with dealing in stolen property, burglary, and marijuana possession in two separate cases. The trial court i…
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FRANK, Chief Judge.
James Satalino was fourteen years old when he committed the crimes of dealing in stolen property, burglary, and possession of marijuana (case number 93-15501), together with another burglary offense (case number 94-00758). At a hearing on February 25, 1994, Satalino appeared before the trial court and learned of the intention to sentence him as an adult despite an HRS recommendation of juvenile sanctions in the predisposition report. Satalino subsequently entered a plea of no contest to the charges, specifically reserving the right to challenge the imposition of adult sanctions. After sentencing, the trial court filed a document entitled “Determination of Suitability of Imposing Adult Sanctions,” which can be characterized as a -form check list.
We must reverse Satalino’s sentence; the trial court failed to make the required individualized findings concerning the suitability of adult sanctions for him. The form order is insufficient to satisfy the prescriptions of section 39.059(7)(c), Florida Statutes (1993), as they were interpreted in Troutman v. State, 630 So. 2d 528 (Fla.1993); Menchaca v. State, 636 So. 2d 178 (Fla. 2d DCA 1994); Hannah v. State, 644 So. 2d 141 (Fla. 2d DCA 1994), and an ever-expanding list of additional cases. On resentencing, the trial court may impose adult sanctions after making the appropriate specific findings in a written order. See Messam v. State, 640 So. 2d 162 (Fla. 5th DCA 1994).
Reversed and remanded for resentencing.
ALTENBERND and LAZZARA, JJ., concur.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By
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Frattallone v. State, 658 So. 2d 1130 (Fla. 2d DCA 1995)…on of a form checklist does not satisfy the requirement of section 39.059(7)(c) that individualized findings be made with regard to each of the criteria set forth in that statute for determining the suitability of adult sanctions. Satalino v. State, 652 So. 2d 1231 (Fla. 2d DCA 1995); Messam v. State, 640 So. 2d 162 (Fla. 5th DCA 1994). Accordingly, we must reverse Frattallone’s sentence and remand for resentencing, at which time the trial court may again impose adult sanctions provided it makes and reduces to…
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Street v. State, 665 So. 2d 359 (Fla. 5th DCA 1995)…ses, or the juvenile’s prior record, is legally insufficient to support the imposition of adult sanctions. See Messam v. State, 640 So. 2d 162 (Fla. 5th DCA 1994); see also Frattallone v. State, 658 So. 2d 1130 (Fla. 2d DCA 1995); Satalino v. State, 652 So. 2d 1231 (Fla. 2d DCA 1995). There are exceptions to a trial court entering detañed written findings. As examples, the trial court is not required to make the written findings if the juvemle has been sentenced previously as an adult or intelligently and kno…
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Stuberfield v. State, 690 So. 2d 636 (Fla. 4th DCA 1997)…Fla. 2d DCA 1995); Philmore v. State, 656 So. 2d 270 (Fla. 4th DCA 1995); Wood v. State, 655 So. 2d 1155 (Fla. 5th DCA 1995); Gammage v. State, 655 So. 2d 183 (Fla. 4th DCA 1995); Crain v. State, 653 So. 2d 442 (Fla. 2d DCA 1995); Satalino v. State, 652 So. 2d 1231 (Fla. 2d DCA 1995); Sales v. State, 652 So. 2d 513 (Fla. 4th DCA 1995). . While Miller applied the older language of ex post facto jurisprudence, in that it spoke of a "disadvantage" to the defendant, the United States Supreme Court has since expla…
Authorities Cited
- Troutman v. State, 630 So. 2d 528 (Fla. 1993)
- Edler v. State, 630 So. 2d 528 (Fla. 1993)
- Menchaca v. State, 636 So. 2d 178 (Fla. 2d DCA 1994)
- Messam v. State, 640 So. 2d 162 (Fla. 5th DCA 1994)
- Hannah v. State, 644 So. 2d 141 (Fla. 2d DCA 1994)