J.J.A., a Child v. State of Florida

Summary

The Fifth District Court of Appeal affirmed the denial of J.J.A.'s motion to suppress but reversed the disposition order adjudicating him delinquent for possession of a firearm by a minor. The court held that the order failed to specify the maximum penalty and predisposition detention credit required by Florida Rule of Juvenile Procedure 8.115(d)(2), and remanded for entry of a corrected order.

Holdings

1. A motion to correct a disposition order filed under Florida Rule of Juvenile Procedure 8.135(b)(2) is reviewed de novo.
2. A juvenile disposition order must specify the maximum penalty defined by statute and the amount of time served in secure detention before disposition.
3. A juvenile is entitled to predisposition credit for time served in secure detention when the commitment is effectively determinate because it necessarily concludes before the juvenile reaches the age at which the Department of Juvenile Justice's authority ends.

Questions Presented

1. Whether the trial court properly denied J.J.A.'s motion to suppress.
2. Whether the disposition order complied with Florida Rule of Juvenile Procedure 8.115(d)(2) by specifying the maximum statutory penalty and predisposition credit for time served.
3. Whether J.J.A. was entitled to predisposition credit because his juvenile commitment was effectively determinate and could not extend beyond the maximum adult punishment.

Disposition

reversed_and_remanded