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CRIMINAL LAW--OFFENSE COMMITTED BY JUVENILE--SENTENCING. The Court held that three concurrent 1,000-year sentences for non-homicide offenses, committed when the defendant was a juvenile, did not violate the Eighth Amendment because the sentences included eligibility for parole. Florida's statutory parole process fulfills the requirement that juveniles be given a "meaningful opportunity" to be considered for release in their lifetime as the process includes initial and subsequent parole reviews based upon individualized considerations before the Florida Parole Commission that are subject to judicial review.
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TORTS--LIMITATION OF ACTIONS--TOLLING--MINORS' CLAIMS. Under section 95.051(1)(h), Florida Statutes, which provides that the statute of limitations is tolled by the minority or previously adjudicated incapacity of the person entitled to sue during any period of time in which a parent, guardian, or guardian ad litem does not exist, the statute of limitations for the minor plaintiffs' negligence claims was tolled during the period when the minors' grandparents had been given custody of the minors but before the grandparents were appointed as permanent guardians, and during the period when the minors were represented by a guardian ad litem in a dependency proceeding but not in the tort action in which the claim to be tolled is being litigated.
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CRIMINAL LAW--EVIDENCE--RULE OF COMPLETENESS--IMPEACHMENT--HEARSAY DECLARANT. The statutory rule of completeness does not apply unless a written or recorded statement is introduced into evidence. In the case at issue, the defendant could not require the state to introduce into evidence the entire video recording of the defendant's statement to police where the state questioned a detective on direct examination about his conversation with the defendant without introducing any portion of the defendant's statement into evidence. Where the defendant invoked the statutory rule of completeness to introduce exculpatory portions of his out-of-court statement into evidence, the defendant was subject to impeachment with his prior convictions for felonies and crimes of dishonesty pursuant to section 90.806(1), which authorizes the impeachment of hearsay declarants. The fact that the state "opened the door" to the introduction of exculpatory hearsay statements of the defendant does not suspend operation of the rule set forth in section 90.806(1).
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