BRENT PAUL VENROOY
v.
STATE OF FLORIDA
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In this Anders appeal, the Fifth District Court of Appeal affirmed Brent Paul Venrooy's judgment and sentence but remanded for correction of the sentencing judgment to strike a $100 investigative cost fee that was never requested by the State.
The court affirmed the judgment and sentence but remanded for entry of a corrected judgment striking the $100 investigative cost fee because investigative costs cannot be imposed without a request from the State.
[1] A trial court may not impose investigative costs on a defendant unless the State has requested such costs.
Previewing 1 of 1 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“the State must request investigative costs to make a defendant liable for those costs”
Establishes the legal requirement that investigative costs cannot be imposed without a state request
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Join FLexlaw to unlock all legal intelligenceBrent Paul Venrooy was convicted and sentenced in the Circuit Court for St. Johns County. The sentencing judgment included a $100 fee for investigativ…
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FIFTH DISTRICT COURT OF APPEAL
STATE OF FLORIDA
Case No. 5D2025-0345 LT Case No. 2023-001316-CFMA
BRENT PAUL VENROOY, Appellant,
v.
STATE OF FLORIDA, Appellee.
On appeal from the Circuit Court for St. Johns County.
R. Lee Smith, Judge.
Thomas J. Butler, of Thomas Butler, P.A., Miami Beach, for Appellant.
James Uthmeier, Attorney General, Tallahassee, and Daniel P. Caldwell, Assistant Attorney General, Daytona Beach, for Appellee.
April 17, 2026
PER CURIAM.
In this Anders¹ appeal, we affirm Appellant's judgment and sentence. However, we remand for the entry of a corrected judgment striking the $100 fee for investigative costs because the
1 Anders v. California, 386 U.S. 738 (1967).
investigative costs were never requested. See Richards v. State, 288 So. 3d 574, 577 (Fla. 2020) (“[T]he State must request investigative costs to make a defendant liable for those costs. . . .").
AFFIRMED and REMANDED with instructions.
JAY, C.J., and LAMBERT and EISNAUGLE, JJ., concur.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Anders v. California, 386 U.S. 738 (U.S. 1967)
- Smith v. State (Fla. 4th DCA 2026)