J.R. v. State

The State filed a petition for delinquency against Minor, alleging that Minor had violated Fla. Stat. Ann. 810.097(2) by trespassing on the grounds of a middle school after having been warned by the principal or designee. The two individuals who gave warnings to Minor were school police officers. The trial court denied Minor's motion and adjudged Minor delinquent. The district court affirmed. Minor appealed, contending (1) the State failed to prove that either of the warning officers was a designee of the school's principal; and (2) because the designee status of the warning individual is an element of the trespass offense under section 810.097(2), the State had failed to prove every element of the crime beyond a reasonable doubt. The Supreme Court quashed the decision of the district court and remanded the case, holding (1) the record did not contain competent, substantial evidence to support the finding that the officers were designees of the school's principal for purposes of section 810.097(2); and (2) therefore, the district court erred in affirming the trial court's adjudication of Minor's delinquency because an essential element of the offense was not supported by competent, substantial evidence. View "J.R. v. State" on Justia Law