Supreme Court of Florida

Jean Claude Noel, Petitioner v. State of Florida, Respondent; Jean Claude Noel, Petitioner, v. State of Florida…

April 21, 2016191 So. 3d 370

Summary

The court held that a sentence reducing a defendant's prison term only if he paid $20,000 in restitution within sixty days violated due process because it imposed two additional years of incarceration based on his inability to pay. The court quashed the district court's decision, approved the conflicting decision to the extent it found the comparable sentence unconstitutional, and ordered resentencing. Justice Canady, joined by Justice Quince, dissented, concluding that the conditional sentence was not so arbitrary or unfair as to violate due process.