The Florida Supreme Court’s Startling Ruling on Juvenile Sentencing

September 22, 2021 Juvenile Offenses

The Court Goes Against Precedent

In March 2020, the Florida Supreme Court ruled that juveniles can be sentenced to terms longer than 20 years in prison without the opportunity of early release. This ruling diverts from precedent, specifically, the 2010 United States Supreme Court case Graham v. Florida which prohibited life sentences without a  “meaningful opportunity” for juveniles convicted of non-homicide crimes to be released. Furthermore, in 2012, Miller v. Alabama held that mandatory life sentences without the possibility of parole cannot be imposed on juveniles convicted of murder. Although juveniles can still face such sentences, judges must first weigh the maturity of the offender and the nature of the crime committed. Following these rulings, the Florida Supreme Court ordered judges to “apply the laws retroactively to inmates who, as juveniles, had been sentenced to life in prison or to terms that would have effectively kept them behind bars until they die.” 

History of the Case at Issue

The case that came before the Florida Supreme Court that led to this divergent ruling centers around Linda Pedroza who helped her boyfriend, Antoine Wright, murder her mother in 2000. Linda was 17 at the time when she and Antoine strangled her mother and then dumped her body in the woods. Eventually, she plead guilty to second-degree murder and was sentenced to 50 years in prison in 2004.  In 2005, the United States Supreme Court ruled in Roper v. Simmons that juveniles younger than 18 cannot be given the death penalty. Miller then added further protection to juveniles by ruling that juveniles, even when charged as adults, cannot be given mandatory life sentences without the possibility of parole. However, because this ruling was interpreted  as only applying to life sentences or lengthy-term of year sentences that would impose imprisonment over the juveniles life, the Florida Supreme held that Linda’s sentence was ineligible for review.

The Case is Revisited

In 2020, Linda’s attorneys argued that her sentence was unconstitutional because the court did not consider her age at the time the offense. However, the state maintained that the sentence was not unconstitutional since she is scheduled to be released from prison when she’s 55. The Fourth District Court of Appeals affirmed, holding there is “no clear, binding Florida Supreme Court decision that requires resentencing.” The Supreme Court agreed, issuing a 15-page opinion and holding:

[T]o the extent this (Supreme) court has previously instructed that resentencing is required for all juvenile offenders serving sentences longer than 20 years without the opportunity for early release based on judicial review, it did so in error.

Therefore, the Supreme Court found that, despite Florida precedent that would require the judge in Linda’s case to assess her maturity before sentencing her, the trial court judge who failed to do so did not err. This is especially troublesome, as Miller recognized and stressed that juveniles’ brains are not fully formed, which often results in poor judgment and susceptibility to negative outside forces. Ultimately, recognizing this gave them a break unless they were deemed “irreparably corrupt.” This sentiment that juveniles should be given leniency in the criminal justice system can be seen through the implementation and use of juvenile diversion programs, which you can read about here. In addition, to read generally about the juvenile justice system in Florida, click here.

Ultimately, this ruling completely strays from the legal guidepost of stare decisis, leading us to question of if the Court can do it in this case, will they do it in others? With laws regarding reproductive justice being challenged in Texas and being questioned across the nation, it leads us to wonder, is straying away from stare decisis really the judicial activism the Court believes it is, or a way to trample the rights already afforded to Floridians and citizens in other states alike.

If you would like to read more about the history of the death penalty in Florida, as well as the Florida Supreme Court’s recent decisions to overturn precedent regarding the death penalty, you can do so here.

Article written by Sarah Kamide

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