Jonathan Conan Riddle, Jr. v. State of Florida

Riddle · Fifth District Court of Appeal of Florida · May 16, 2025 · No. 5D2024-0298

Summary

The Fifth District Court of Appeal of Florida affirmed the denial of Jonathan Riddle’s motion to correct sentencing error concerning three $100 costs of prosecution imposed after his pleas in three criminal cases. The court held that the minimum costs were mandatory even without a request by the State and certified conflict with D.L.J. v. State.

Holdings

  1. Minimum costs of prosecution are mandatory and must be imposed even when the State has not requested them.

Questions Presented

  1. Whether the trial court erred by imposing the mandatory minimum costs of prosecution without a request from the State.

Disposition

affirmed

Cases Cited (4)

  • D.L.J. v. State, 331 So. 3d 227, 228 (Fla. 2d DCA 2021)(conflict certified)
  • Catledge v. State, 391 So. 3d 982, 983 (Fla. 5th DCA 2024)(followed)
  • O'Malley v. State, 378 So. 3d 672 (Fla. 5th DCA 2024)(followed)
  • Parks v. State, 371 So. 3d 392, 392-93 (Fla. 1st DCA 2023)(followed)

Cited In (0)

No citing cases on record yet.

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