J.G.N. v. State, 2026 Fla. App. LEXIS 6221 (Fla. Ct. App. 2026)

The Florida 6th District Court of Appeal held that a probation condition “prohibiting [the youth] from associating with anyone designated by the juvenile probation officer or a parent/guardian” was invalid because the condition is not reasonably related to the underlying adjudication or “future criminality” as required under state statute. The court stated in relevant part:

The condition has no apparent relationship to the crime of battery on a law enforcement officer (BOLEO), as association with designated persons in the abstract is unrelated to BOLEO generally or the BOLEO committed by Appellant. The condition does not relate to conduct that is criminal in nature, as it is not a crime for a person convicted of the crime of BOLEO to associate with designated persons. And the condition does not require or forbid conduct that is reasonably related to future criminality, as we fail to see how prohibiting a person convicted of the crime of BOLEO from associating with designated persons—without the condition including at least some specificity regarding the class or classes of persons that fall within the ambit of designated persons—is reasonably related to future criminality