State v. Sawyer
The State appealed a downward departure sentence of probation imposed after the defendant pled no contest to drug trafficking charges, where the trial court cited the defendant's renal failure and need for dialysis as justification. The Fifth DCA reversed, holding that the unsworn letter from a social worker, medical records, defendant's own testimony, and defense counsel's representations were all insufficient to establish the statutory elements of physical disability, specialized treatment, and amenability to treatment required under section 921.0026(2)(d).
Key facts
- Defendant pled no contest to drug trafficking charges and received a downward departure sentence of probation based on trial court's findings regarding defendant's renal failure and dialysis needs.
- State appealed, arguing the trial court lacked sufficient evidence to support the downward departure under the statutory physical disability provision, citing only an unsworn social worker letter, medical records, defendant's testimony, and defense counsel's representations.
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Why it matters
This opinion reinforces the specific evidentiary showing required to justify a downward departure sentence based on a defendant's medical condition, confirming that unsworn letters, lay testimony, and attorney proffers… — full analysis with a trial
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