Treacy v. Lamberti

Summary

The Florida Supreme Court held that a juvenile charged as an adult with attempted first-degree murder was entitled to pretrial release on reasonable conditions under article I, section 14, of the Florida Constitution. Because Florida law did not provide a parole opportunity satisfying Graham v. Florida, the juvenile could not legally be sentenced to life imprisonment, and the charged offense therefore was not an offense punishable by life imprisonment for purposes of the constitutional bond provision. The court quashed the Fourth District Court of Appeal’s decision.

Holdings

1. Because Florida provided no parole opportunity for juveniles sentenced to life imprisonment, Graham v. Florida prevented Treacy from receiving a life sentence under the law then in effect.
2. A juvenile who cannot legally be sentenced to life imprisonment is not charged with an offense punishable by life imprisonment under article I, section 14, and therefore is entitled to pretrial release on reasonable conditions unless the constitutional detention criteria are met.

Questions Presented

1. Whether Graham v. Florida's prohibition on life-without-parole sentences for juvenile offenders who did not commit homicide affects whether such a defendant is charged with an offense punishable by life imprisonment under article I, section 14, of the Florida Constitution.
2. Whether a juvenile charged as an adult with attempted first-degree murder with a deadly weapon is entitled to pretrial release on reasonable conditions as a matter of right when the juvenile cannot legally be sentenced to life imprisonment.

Disposition

quashed