Supreme Court of Florida

Laveress Hopkins v. State of Florida

September 13, 201237 Fla. L. Weekly Supp. 551

Summary

The court held that the battery-by-detainee enhancement applies when a juvenile commits a battery while detained in a juvenile detention center because such a center is an "other detention facility" under section 784.082. Applying de novo review, the court concluded that the statute is unambiguous, that its plain meaning includes juvenile detention centers, and that the rule of lenity therefore does not apply. The court approved the reversal of the dismissal and rejected the contrary district-court interpretation.