Luke Oliver Davis v. State of Florida

CourtDistrict Court of Appeal of Florida
DecidedJune 17, 2026
Docket1D2024-2407
StatusPublished

This text of Luke Oliver Davis v. State of Florida (Luke Oliver Davis v. State of Florida) is published on Counsel Stack Legal Research, covering District Court of Appeal of Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Luke Oliver Davis v. State of Florida, (Fla. Ct. App. 2026).

Opinion

FIRST DISTRICT COURT OF APPEAL STATE OF FLORIDA _____________________________

No. 1D2024-2407 _____________________________

LUKE OLIVER DAVIS,

Appellant,

v.

STATE OF FLORIDA,

Appellee. _____________________________

On appeal from the Circuit Court for Bay County. Timothy Register, Judge.

June 17, 2026

BILBREY, J.

Appellant challenges his 150-month prison sentence following his no contest plea to one count of lewd and lascivious battery in violation of section 800.04(4), Florida Statutes (2020). We affirm as explained below.

The victim was thirteen years old and Appellant twenty at the time of the offense. In exchange for the plea, the State dismissed two other counts of the same charge and dismissed a single count of interfering with the custody of a minor. The plea agreement provided that sentencing would be at the sole discretion of the court. After conducting a colloquy, the sentencing court accepted the plea and set a sentencing hearing. Appellant sought a downward departure sentence under section 921.0026, Florida Statutes (2020); that Appellant be sentenced as a youthful offender under section 958.04; and that the adult-on-minor sentencing multiplier in section 921.0024(1)(b) not be imposed. In a sentencing memorandum and exhibits, Appellant provided various bases to support his requests including that his neurocognitive developmental disability meant that he functioned at younger age socially and emotionally.

At the sentencing hearing, the court determined that there was no statutory basis to override the adult-on-minor multiplier in section 921.0024(1)(b). The court then heard testimony including expert testimony about Appellant’s disability and that his capacity to appreciate the nature of his criminal conduct was substantially impaired. See § 921.026(2)(k), Fla. Stat. After hearing argument from counsel, the sentencing court denied a downward departure sentence or youthful offender sentencing. The court then imposed a 150-month prison sentence, which was the lowest permissible sentence on Appellant’s criminal punishment code scoresheet.

Following sentencing, Appellant moved to disqualify the sentencing judge. Because the motion to disqualify did not toll the time to file an appeal, Appellant thereafter filed his notice of appeal. Appellant then filed a motion to have a new judge assigned to his case because the sentencing judge did not rule on the motion to disqualify within 30 days. See Fla. R. Gen. Prac. & Jud. Admin. 2.330(l).

After the successor judge was assigned, Appellant moved for reconsideration on certain rulings by the sentencing judge. The successor judge determined that he had no jurisdiction to consider the motion because of the notice of appeal.

Appellant then filed a motion to correct sentencing error under rule 3.800(b), Florida Rules of Criminal Procedure, claiming the sentencing judge failed to permit Appellant his right of allocution at sentencing. The successor judge denied the motion finding that it was sufficient for the sentencing court to ask defense counsel “if the defense had anything else it wanted to address.”

2 Appellant filed a second rule 3.800(b) motion arguing error by the sentencing court in applying the adult-on-minor scoresheet multiplier. The successor judge denied that motion, and this appeal followed.

Here, Appellant first argues that it was error when the sentencing judge did not announce any reasons for denying the requested downward departure sentence or youthful offender sentence. Questions of law arising from sentencing are subject to de novo review. Sanders v. State, 35 So. 3d 864, 868 (Fla. 2010).

Until very recently, whether Appellant’s claim is one of sentencing error or an error in the sentencing process would determine whether he is permitted to raise this issue on appeal. See Emerson v. State, 412 So. 3d 917, 918–19 (Fla. 1st DCA 2025) (holding that under the previous version of Rule of Appellate Procedure, appeals claiming error in the sentencing process were not permitted after a guilty or no contest plea). Following a rule amendment effective as of June 1, 2026, after a defendant enters a guilty or no contest plea, that defendant may appeal both a “sentencing error, if preserved” and “an error in the sentencing process, if preserved.” Fla. R. App. P. 9.140(2)(A)(ii)d.–e.; In re Admin. to Fla. Rule App. P. 9.140, 428 So. 3d 85, 87 (Fla. 2026). At sentencing, Appellant did not argue that a sentencing judge must announce reasons for declining to impose a departure or youthful offender sentence. Accordingly, regardless of whether this claim is sentencing error or an error in the sentencing process, those issues were not preserved, so we cannot consider them.

Even if preserved, failing to announce the reasons for declining to impose a departure sentence or youthful offender sentence would not be error. Section 921.002(1)(f), Florida Statues, permits a court to impose a sentence below the guidelines. But section 921.002(3) then states, “Any sentence imposed below the lowest permissible sentence must be explained in writing by the trial court judge.” Likewise, rule 3.703(d)(30)(A), Florida Rules of Criminal Procedure, provides, “If a sentencing judge imposes a sentence that departs from the recommended guidelines sentence, the reasons for departure shall be orally articulated at the time sentence is imposed.” The youthful offender statute also requires

3 a written explanation by the sentencing judge when a youthful offender sentence is imposed. § 958.04(3), Fla. Stat.

But no rule or statute requires a sentencing court to set forth its reasons for refusing to impose a departure or youthful offender sentence. Barring some exceptions that do not apply here, a sentencing court is allowed to “impose a sentence up to and including the statutory maximum” with no requirement for providing any explanation for such sentence. § 921.002(1)(g), Fla. Stat.

“Had the trial court refused even to consider a departure because of an erroneous conclusion about its authority to do so, the refusal would have been an infringement of a statutory right, one we then would have the authority to remedy.” Gazoombi v. State, 406 So. 3d 371, 379 (Fla. 1st DCA 2025) (en banc). The same is true when a sentencing court has a “misapprehension of its sentencing authority” under the youthful offender statute. Stewart v. State, 201 So. 3d 1258, 1260 (Fla. 1st DCA 2016). But we will not impose on the circuit courts a requirement in pronouncing sentence beyond what the constitution, statutes, or Rules of Criminal Procedure require.

Appellant next argues that it was error when the sentencing court imposed the adult-on-minor multiplier, doubling the sentence points on his scoresheet. Appellant’s second rule 3.800(b) motion preserved this issue for our consideration. 1 This issue we also review de novo. See State v. Hardley, 344 So. 3d 638, 640 (Fla. 1st DCA 2022) (“[W]here the issue presented is a pure question of law involving statutory interpretation, the standard of review is de novo.”).

Section 921.0024(1)(b), which contains the adult-on-minor multiplier, is not a model of clarity. It provides in part:

Adult-on-minor sex offense: If the offender was 18 years of age or older and the victim was younger than 18

1 In Jackson v. State, 983 So. 2d 562, 572 (Fla. 2008), scoresheet error was held to be sentencing error that could be preserved with a motion under rule 3.800(b).

4 years of age at the time the offender committed the primary offense, and if the primary offense was an offense committed on or after October 1, 2014, and is a violation of s. 787.01(2) or s.

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Related

Sanders v. State
35 So. 3d 864 (Supreme Court of Florida, 2010)
Jackson v. State
33 Fla. L. Weekly Fed. S 357 (Supreme Court of Florida, 2008)
Terry D. Ellison, Jr. v. State of Florida
268 So. 3d 1007 (District Court of Appeal of Florida, 2019)
Albert James Hayes, II v. State of Florida
272 So. 3d 815 (District Court of Appeal of Florida, 2019)
Stewart v. State
201 So. 3d 1258 (District Court of Appeal of Florida, 2016)

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Luke Oliver Davis v. State of Florida, Counsel Stack Legal Research, https://law.counselstack.com/opinion/luke-oliver-davis-v-state-of-florida-fladistctapp-2026.