Quinton Marcus Reddick v. State of Florida

Summary

The First District Court of Appeal of Florida, on rehearing, affirmed Quinton Marcus Reddick’s fifteen-year prison sentence for violating probation. The court rejected his arguments concerning suppression of evidence, an alleged error in the violation-of-probation affidavit, and prosecution costs, holding that the evidence supported the probation violations and that no due process violation occurred.

Holdings

1. Reddick's first two suppression arguments were moot because the district court had already reversed the suppression order in the related criminal case.
2. The apparent unintentional error in the amended violation-of-probation affidavit did not establish a due-process violation because the evidence supported the alleged violation, the parties understood the issue, and Reddick received full due process regarding the violations of the standard condition.
3. The probation violation was adequately supported by the evidence of a violation of special condition 29 and by the nine alleged violations of the standard condition requiring Reddick to live without violating any law.
4. Reddick's challenge to the prosecution costs failed under current Florida law.

Questions Presented

1. Whether Reddick's suppression arguments concerning evidence underlying the probation-violation charges remained justiciable after the district court reversed the suppression order in the related criminal case.
2. Whether an apparent scrivener's error in the amended violation-of-probation affidavit deprived Reddick of due process or prevented a finding that he violated special condition 29.
3. Whether the evidence supported a finding that Reddick violated special condition 29 and the standard condition requiring him to live without violating any law.
4. Whether the assessment of prosecution costs was permissible under current law.

Disposition

affirmed