ISAAC L. JOHNSON, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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Johnson appealed the denial of his postconviction motion under Florida Rule of Criminal Procedure 3.800(a), challenging his loss of youthful offender status following probation revocation. The court affirmed the denial of his first three claims but reversed as to his fourth claim, holding that the trial court was required to maintain his youthful offender designation and must correct his sentencing documents to reflect this status.
The trial court was required to continue the appellant's youthful offender status upon resentencing following probation violation. Omission of the youthful offender designation from sentencing documents is correctable error under Rule 3.800(a), not merely cases where the designation is expressly revoked.
[1] A trial court must continue a defendant's youthful offender status upon resentencing following a probation violation.
[2] A defendant is entitled to relief when youthful offender status is omitted from sentencing documents following a probation violation, even if the designation was not expr…
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Join FLexlaw to unlock all legal intelligence“The trial court was required to continue the appellant's youthful offender status upon his resentencing following the violation of his probation.”
Establishes the core legal principle that youthful offender status must be maintained upon resentencing after probation violation.
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Join FLexlaw to unlock all legal intelligenceJohnson originally pled nolo contendere to multiple felonies across five separate cases and was sentenced as a youthful offender to 4 years in prison …
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The appellant challenges the denial of his postconviction motion brought pursuant to Florida Rule of Criminal Procedure 3.800(a). As to his first three claims, we affirm without comment. As to his fourth claim, we reverse and remand.
The appellant originally pled nolo con-tendere to multiple felonies in five separate eases. Pursuant to a negotiated plea agreement, he was sentenced as a-youthful offender to a total of 4 years in prison followed by 2 years on probation. In 2009, he admitted to violating his probation and was sentenced to a total of 172 months in prison. In 2011, he was resentenced based upon a successful postconviction motion to the same 172-month total sentence.
In 2014, the appellant filed the instant rule 3.800(a) motion, arguing in ground four that the trial court improperly failed to maintain his youthful offender designation upon the revocation of his probation. The trial court denied this claim, concluding that the designation was never expressly revoked. However, none of the sentencing documents entered following the revocation of the appellant’s probation reflect that he maintained his youthful offender status.
The trial court was required to continue the appellant’s youthful offender status upon his resentencing following the violation of his probation. See Lee v. State, 67 So.3d 1199, 1202 (Fla. 2d DCA 2011) (citing State v. Arnette, 604 So.2d 482, 484 (Fla.1992); Blacker v. State, 49 So.3d 785, 788 (Fla. 4th DCA 2010); and Gardner v. State, 656 So.2d 933, 937 (Fla. 1st DCA 1995)). Relief under these circumstances is not reserved solely for those .cases wherein the trial court has expressly revoked the youthful offender designation. Rather, it has also been granted where the youthful offender designation is omitted from the sentencing documents. See Mosley v. State, 134 So.3d 1124, 1124-25 (Fla. 4th DCA 2014) (concluding that the omission of the defendant’s youthful offender status from his written sentencing documents was an error that could be corrected at any time pursuant to rule 3.800(a)).
Accordingly, we reverse and remand the denial of the appellant’s fourth claim with directions for the trial court to correct the appellant’s sentencing documents to reflect his youthful offender status. See Larkins v. State, 159 So.3d 386, 386 (Fla. 4th DCA 2015). The appellant need not be-present for this correction. See id.
AFFIRMED IN PART; REVERSED IN PART, AND REMANDED.
ROBERTS, C.J.', ROWE and MAKAR, JJ., concur.
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Citator
Authorities Cited
- LEE v. State, 67 So. 3d 1199 (Fla. 2d DCA 2011)
- Blacker v. State, 49 So. 3d 785 (Fla. 4th DCA 2010)
- State v. Arnette, 604 So. 2d 482 (Fla. 1992)
- Gardner v. State, 656 So. 2d 933 (Fla. 1st DCA 1995)
- Johnie Earl Larkins v. State, 159 So. 3d 386 (Fla. 4th DCA 2015)
- Mosley v. State, 134 So. 3d 1124 (Fla. 4th DCA 2014)