Christian v. State
Christian v. State, 84 So. 3d 437 (2012)
Winning Party
State of Florida
Key Issue
Motion to Correct Illegal Sentence (Rule 3.800(a))
Case Type
CRIMINAL
Facts
•
Christian was not charged with a new crime related to his marijuana use but admitted to it.
•
The trial court revoked his probation and sentenced him to concurrent terms of ten years in state prison on the charges.
•
Christian was originally sentenced pursuant to the Florida Youthful Offender Act to concurrent split sentences on charges of aggravated assault against a law enforcement officer (with a firearm) and aggravated battery with a deadly weapon.
•
Christian violated his youthful offender probation by using marijuana.
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After serving the prison portion of these sentences, and while on youthful offender probation, Christian violated his probation by using marijuana.
•
Christian was not charged with a new crime related to his illicit drug use but admitted to using marijuana.
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Key Holdings
•
The trial court did not err in sentencing Christian to ten years in prison because his violation of probation (marijuana use) constitutes a substantive violation, allowing for a sentence longer than six years under the Youthful Offender Act.
Citations
Christian v. State, 84 So. 3d 437, 2012 WL 1121748, 2012 Fla. App. LEXIS 5291 (2012)
Legal Reasoning
The court relied on its precedent in Robinson v. State, which held that illicit drug use constitutes a substantive violation of youthful offender probation, even if the state does not file new charges based on the drug use. The court also noted that this holding has been consistently followed and cited with approval by the Florida Supreme Court and other district courts of appeal. The court certified conflict with Rogers v. State, due to a potential misinterpretation of the requirements for establishing a substantive violation of youthful offender probation, particularly regarding whether a new conviction is required.
Outcome
The denial of Christian's rule 3.800(a) motion to correct illegal sentence is affirmed. The court certified conflict with Rogers v. State.
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