Jackson v. State

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Appellant was convicted of one count of robbery with a firearm while wearing a mask. Appellant was twenty years old when he committed the crime but twenty-one years old when he was tried and sentenced. If Appellant had been sentenced under the youthful offender statute, he faced a six-year cap as to his sentence. Instead, Appellant was sentenced to the statutory maximum of life in prison. Appellant filed a motion to correct an illegal sentence. The motion was deemed denied. The Court of Appeal affirmed the sentence. Before the Supreme Court, Appellant raised a facial challenge to the constitutionality of Fla. Stat. 958.04(1)(b), arguing that the statute (1) violates equal protection because the age-at-sentencing classification creates arbitrary and irrational distinctions between otherwise eligible defendants, and (2) violates due process because, in attempting to be eligible for youthful offender sentencing, a defendant may forgo certain constitutional rights. The Supreme Court affirmed, holding (1) because section 958.04(1)(b), as amended, bears a rational relationship to a legitimate government objective, it does not violate equal protection; and (2) the statute does not violate due process because it serves a legitimate state interest. View "Jackson v. State" on Justia Law