Numerous Florida cases have recognized the distinction between substantive versus technical/nonsubstantive violations set forth in the statute at issue here. See, e.g., Wilkey v. State, 712 So.2d 847 (Fla. 4th DCA 1998) (remanding for an evidentiary hearing in a post conviction proceeding where youthful offender challenged length of sentence imposed after probation violation because record did not reveal whether violation was substantive or technical); see also Quiles v. State, 777 So.2d 992 (Fla. 2d DCA 2000); Escutary v. State, 753 So.2d 650 (Fla. 3d DCA 2000);Johnson v. State, 736 So.2d 708 (Fla. 2d DCA 1999); Robinson v. State, 702 So.2d 1346 (Fla. 5th DCA 1997); Hill v. State, 692 So.2d 277 (Fla. 5th DCA 1997); Johnson v. State, 678 So.2d 934 (Fla. 3d DCA 1996); Dunbar v. State, 664 So.2d 1093 (Fla. 2d DCA 1995); Reeves v. State, 605 So.2d 562 (Fla. 2d DCA 1992). While no Florida decision until Meeks had undertaken the task of specifically defining "substantive" or "technical/nonsubstantive," we do gain some insight through an analysis of how specific violations have been classified by various courts.
Additionally, the First District Court of Appeal stated that “a trial court may impose a non-youthful offender sentence on a youthful offender who commits violations of probation that involve new substantive offenses ... [and] the trial court [is] not limited to a youthful offender sentence.” Willis v. State, 744 So.2d 1265, 1266 (Fla. 1st DCA 1999) (citing Hill v. State, 692 So.2d 277, 278 (Fla. 5th DCA 1997) (stating that a trial court is permitted to exceed youthful offender maximum sentences); Johnson v. State, 678 So.2d 934, 934–35 (Fla. 3d DCA 1996) (providing that a youthful offender may be sentenced as a non-youthful offender for commission of a substantive violation while on probation); Dunbar v. State, 664 So.2d 1093, 1094 (Fla. 2d DCA 1995)). Accordingly, it is within the trial court's discretion to determine whether a youthful offender should be sentenced as such, or if it should impose a non-youthful offender sentence when a substantive violation occurs.