CARL INGRAHAM
v.
STATE OF FLORIDA

Fla. 4th DCA | 2026-06-03
No. 2025-0426
Linn, J., Ciklin, J., Gerber, J., Lott, J.
2026 FL 6625 Florida District Court of Appeal, Fourth District (2026)

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Holding

A trial court's oral pronouncement of sentence controls over the written sentencing document when the two conflict.


Headnotes

[1] A trial court's oral pronouncement of sentence controls over the written sentencing document when the two conflict, requiring remand for correction.

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Key Quotes

“a court's oral pronouncement of a sentence controls over the written sentencing document”

The court cited Williams v. State, 957 So. 2d 600, 603 (Fla. 2007) for the principle that oral pronouncements control written documents in sentencing.

Facts & Procedural History

Ingraham was convicted of DUI manslaughter, vehicular homicide, and DUI causing serious bodily injury following a fatal crash. The trial court imposed…

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Opinion of the Court

DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA

FOURTH DISTRICT

CARL INGRAHAM, Appellant,

v.

STATE OF FLORIDA, Appellee.

No. 4D2025-0426

[June 3, 2026]

Appeal from the Circuit Court for the Nineteenth Judicial Circuit, St. Lucie County; Michael James Linn, Judge; L.T. Case No. 562017CF001431AXXXXX.

Daniel Eisinger, Public Defender, and Siobhan Shea, Assistant Public Defender, West Palm Beach, for appellant.

James Uthmeier, Attorney General, Tallahassee, and Pablo Ignacio Tapia, Assistant Attorney General, West Palm Beach, for appellee.

PER CURIAM.

Appellant raises five issues on appeal arising from his convictions for DUI manslaughter, vehicular homicide, and DUI causing serious bodily injury following a fatal crash. With one exception, we affirm without comment.

As to sentencing, the State properly concedes error regarding certain costs because “a court's oral pronouncement of a sentence controls over the written sentencing document.” Williams v. State, 957 So. 2d 600, 603 (Fla. 2007). We therefore reverse and remand for correction of costs only.

We otherwise affirm.

Affirmed in part, reversed in part, and remanded.

CIKLIN, GERBER and LOTT, JJ., concur.

* * *

Not final until disposition of timely-filed motion for rehearing.


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