Florida Court Examines What Constitutes a Reasonable Seizure of a Juvenile

Underage people living in Florida have the same rights as adults with regard to criminal investigations. In other words, they have the right to be free from unreasonable searches and seizures. As such, if the police impermissibly detain a minor, the minor arguably cannot be deemed guilty of the commission of any offenses that happen during their detention. Recently, a Florida court examined what constitutes a reasonable seizure of a minor in a case in which a juvenile defendant challenged her adjudication of delinquency for battery on a police officer. If you are currently charged with committing a crime as a juvenile, it is critical to speak to a Clearwater juvenile defense attorney to determine what defenses you might be able to set forth.

Facts of the Case

It is reported that a police officer observed the defendant sitting in a corner near the entrance of a high school after the school was closed. Out of concern for the defendant, who was a young female alone at night in an area with a high rate of crime, the officer approached the defendant and began questioning her. The defendant was reluctant to provide the officer with information; she stated she was waiting for a bus but did not have any bus information, and she declined to tell him her parents’ full names or her address.

Reportedly, the officer called for backup, after which the defendant ran away. The officers pursued the defendant on foot, caught and handcuffed her, and placed her in the back of a police vehicle. They checked on her about half an hour later and found her kicking the partition between the seats. They attempted to restrain her, and she kicked one of the officers in the chest. She was charged with battery of an officer but moved for judgment of dismissal on the grounds that her seizure was illegal. The court found her guilty, and she appealed.

Reasonable Seizure of a Juvenile

Under Florida law, battery is a third-degree offense when committed against a police officer engaged in the lawful performance of their duties. The Florida statutes do not define the phrase “lawful performance of duties,” but the Florida Supreme Court has stated that courts must employ the legal standards governing the duty the police officer was undertaking at the time of the battery.

As such, the court in the subject case was tasked with determining whether the officer lawfully detained the defendant. The court explained that even absent reasonable suspicion of criminal activity, an officer may detain a person pursuant to a community caretaking duty under certain circumstances. The court elaborated that the touchstone of any Fourth Amendment Analysis, including those involving welfare checks, is reasonableness.

Here, the court found that the officer’s actions were reasonable throughout his encounter with the defendant. Specifically, that the detainment of the defendant was a reasonable extension of the officer’s community caretaking function. Thus, it affirmed the defendant’s conviction.

Talk to a Dedicated Clearwater Attorney

An adjudication of delinquency can be detrimental to a juvenile defendant’s education and job prospects, as well as their reputation. If you are accused of violating the law as a juvenile, it is in your best interest to talk to an attorney about your rights. The dedicated Clearwater juvenile defense attorneys of Hanlon Law can assess the facts of your case and aid you in pursuing the best legal outcome available. You can reach Hanlon Law through the online form or by calling 727-897-5413 to set up a conference.


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