## Facts

- L.M., age 13, pleaded guilty to petit larceny and was adjudicated delinquent after a history of prior offenses.
- A predisposition report described L.M. as “ungovernable” and warned that his mother was likely to lose control without firm measures.
- At an earlier disposition, the court required L.M. to attend youth programs at his mother’s church and to contact the church pastor; that condition was reversed on appeal because it risked religious compulsion and delegated rehabilitative choices to a pastor.
- On remand, the trial court revised the condition to require L.M. to obey all lawful and reasonable requirements imposed by his mother, “whether related to school, civic, church, or community programs.”
- L.M. appealed the revised condition, arguing (1) unlawful delegation of judicial authority to his mother and (2) a violation of his federal and state constitutional rights to free exercise of religion.

## Issues

1. Whether a juvenile probation/community-control condition requiring obedience to all “lawful and reasonable” parental requirements (including those involving church-related programs) is an improper delegation of the court’s sentencing authority.
2. Whether the revised condition, on its face, violates constitutional protections concerning religious exercise by potentially compelling participation in church-related activities.

## Decision

- The appellate court affirmed the revised probation/community-control condition.
- The court held the condition did not improperly delegate a judicial function because it set an objective limitation (“lawful and reasonable”) and left ultimate oversight with the court.
- The court held the condition did not facially violate religious-exercise protections because it was neutral in form and did not specifically mandate religious participation or place rehabilitative decisions in the hands of a religious official.

## Legal Principles

- A juvenile probation condition may require the child to obey a parent’s lawful and reasonable directives as part of supervision and rehabilitation, without constituting an unconstitutional delegation, where the court retains authority to address unlawful or unreasonable demands.
- A condition is constitutionally problematic when it specifically compels religious participation or assigns a religious official decision-making authority over a juvenile’s rehabilitative programming.
- Facial challenges based on possible future religious coercion generally require more than speculation; objections may depend on whether a particular directive is unlawful or unreasonable in application.

## Conclusion

The court upheld a juvenile probation condition requiring obedience to a parent’s lawful and reasonable requirements, including those related to church programs, because it restored parental supervision without transferring judicial authority and did not, by its terms, compel religious activity.


L.M. v. State, 610 So. 2d 1314 (Fla. 1st DCA 1992)