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Carnegie v. State

District Court of Appeal of Florida
473 So. 2d 782 (1985)
ELI5:

Rule of Law:

A trial court may not delegate its exclusive judicial responsibility to articulate the reasons for a departure from sentencing guidelines to the state attorney's office.


Facts:

  • Michael Carnegie was charged with battery and burglary of a dwelling.
  • The opinion does not provide any other substantive facts regarding the underlying criminal acts.

Procedural Posture:

  • Michael Carnegie was prosecuted by the State of Florida in a trial court and convicted of battery and burglary of a dwelling.
  • At sentencing for the burglary charge, the trial court departed from the recommended guideline range of twelve to thirty months imprisonment and imposed a fifteen-year sentence.
  • The court gave no oral or written reasons for the departure, instead directing the state attorney's office to prepare and submit written reasons for the court to incorporate later.
  • Carnegie (appellant) appealed his judgment and sentence to the District Court of Appeal of Florida, Second District, arguing against the State of Florida (appellee).

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Issue:

Does a trial court improperly delegate its judicial function when, without articulating any reasons itself, it directs the state attorney's office to prepare and submit the written reasons for a departure from sentencing guidelines?


Opinions:

Per curiam - Per Curiam

Yes. A trial court improperly delegates its judicial function by ordering the state to provide reasons for a sentencing departure. The responsibility to articulate reasons for departing from the sentencing guidelines belongs exclusively to the court. While oral reasons stated on the record are sufficient under Florida Rule of Criminal Procedure 3.701(d)(11), the trial court in this case articulated no reasons whatsoever. A court's mere statement that it will incorporate reasons to be submitted later by the prosecution fails to meet the statutory requirement that the court itself must provide the justification for the sentence.



Analysis:

This decision reinforces the principle of judicial independence and accountability in sentencing. It establishes a clear boundary, prohibiting judges from outsourcing the critical task of justifying a sentence to the prosecution. This ensures that the reasoning for a defendant's sentence originates from the neutral arbiter, not one of the adversarial parties. The ruling protects the integrity of the appellate review process, which depends on a clear record of the trial court's own reasoning for its decisions.

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