J.H. AND C.H., APPELLANTS,
v.
STATE OF FLORIDA, APPELLEE
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The court reversed the juvenile arson convictions because the evidence failed to negate a reasonable hypothesis of accidental fire, and affirmed in part and reversed in part the probation conditions, striking the prohibition on organized sports as not reasonably related to rehabilitation.
Evidence insufficient to support arson conviction where a reasonable hypothesis of innocence exists that the fire was purely accidental.
[1] In a juvenile arson prosecution, evidence is insufficient to support conviction where it fails to negate a reasonable hypothesis of innocence that the fire was accidental…
[2] A probation condition prohibiting participation in organized sports is not reasonably related to rehabilitation and therefore violates statutory requirements.
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Join FLexlaw to unlock all legal intelligenceTwo juveniles were adjudicated guilty of first-degree felony arson of a dwelling under Florida Statutes section 806.01(l)(a), and simultaneously convi…
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J.H. and C.H. (“appellants”) appeal the Juvenile Disposition Orders adjudicating each of them guilty of first-degree felony arson of a dwelling, contrary to section 806.01(l)(a), Florida Statutes, arguing the trial court erred in denying their motion for a judgment of dismissal of the charged offense. We review this issue de novo. See J.W.J. v. State, 994 So.2d 1223, 1224 (Fla. 1st DCA 2008). Because we conclude the evidence failed to negate appellants’ reasonable hypothesis of innocence that the incident was purely accidental, we reverse the trial court’s denial of the motion and remand with directions that in lower court case numbers 2011-CJ-695 and 2011-CJ-696, appellants are to be discharged. See T.E. v. State, 701 So.2d 1237 (Fla. 3d DCA 1997).
Simultaneous to their adjudications and sentencing in the above two cases, in case numbers 2011-CJ-698 and 2011-CJ-699, appellants were found guilty of, and were sentenced for, criminal mischief. Appellants now challenge the legality of two *1250of the conditions of probation that were imposed in all four cases. We affirm one of the conditions without further comment, but conclude the state properly conceded error as to that condition prohibiting appellants from participating in organized sports, as not being “reasonably related to rehabilitation.” Stephens v. State, 659 So.2d 1303, 1304 (Fla. 1st DCA 1995).
AFFIRMED, in part, REVERSED, in part, and REMANDED for further proceedings consistent with this opinion.
DAVIS, RAY, and SWANSON, JJ., concur.
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Citator
Cited By
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J.R.M. v. State, 228 So. 3d 1147 (Fla. 4th DCA 2017)…the special condition factors. There is no relationship between the crimes committed and the condition. Nor is it related to future criminality. It is not reasonably related to his rehabilitation.. The condition should be stricken.1 J.H. v. State, 107 So. 3d 1249, 1249 (Fla. 1st DCA 2013) is persuasive concerning the court’s prohibiting of the juvenile’s participation in sports. There, the First District struck a condition prohibiting a juvenile from participating in sports because it was not reasonably rela…
Authorities Cited
- J.W.J. v. State, 994 So. 2d 1223 (Fla. 1st DCA 2008)
- Stephens v. State, 659 So. 2d 1303 (Fla. 1st DCA 1995)
- T.E. v. State, 701 So. 2d 1237 (Fla. 3d DCA 1997)