D.M.T. v. State
The Third DCA affirmed a juvenile's adjudication for trespass within a school safety zone, holding that because D.M.T.'s own conduct (returning to school property during a suspension after multiple warnings) fell squarely within the statute's proscriptions, he lacked standing to raise a facial vagueness challenge to § 810.0975(2)(b). The court also held the officer's testimony about a prior trespass warning was properly admitted to show notice/knowledge rather than propensity, and found the Richardson-inquiry and burden-shifting arguments unpreserved.
Key facts
- D.M.T., a juvenile, was adjudicated delinquent for trespass within a school safety zone under § 810.0975(2)(b) after returning to school property during a suspension despite multiple warnings.
- The trial court admitted evidence of a prior uncharged trespass warning to establish D.M.T.'s knowledge and notice that he could not be on school grounds.
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Why it matters
This opinion reinforces the threshold standing requirement for facial vagueness challenges in Florida—counsel must show their client's conduct falls outside the statute's core proscriptions before a vagueness argument… — full analysis with a trial
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