David Puzio v. State of Florida

Summary

The court quashed the district court’s remedy for a harmful sentencing error involving a juvenile offender and held that the offender must receive a de novo resentencing under the statutory provision applicable when the required enhancement fact was not found by a jury. A ministerial correction was inadequate because it did not provide the constitutional sentencing proceeding required after the Alleyne error. The court declined to decide whether a jury could be empaneled on resentencing because that issue was not properly preserved or fully briefed.