KENNETH WAYNE TOWNSEND
v.
STATE OF FLORIDA

Fla. 5th DCA | 2025-07-25
No. 2024-1379
Smith, R. Lee, Harris, J., Kilbane, J., MacIver, J.
2025 FL 6420 Florida District Court of Appeal, Fifth District (2025)

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Holding

A trial court may not assess costs of investigation under section 938.27, Florida Statutes, without a request from the State, and must correct a sentencing scoresheet to remove enhancements the court orally declined to impose.


Headnotes

[1] Costs of investigation under section 938.27, Florida Statutes, that are not mandated in a minimum amount by statute must be requested and established by the State and can…

[2] A sentencing scoresheet must be corrected to remove enhancements that the trial court orally declined to impose at sentencing.

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Key Quotes

“It is axiomatic that costs not mandated in a minimum amount set by statute will have to be requested—and established—by the State. Because they must be proven, they must be requested.”

Court citing Parks v. State regarding the requirement that non-mandatory costs be requested by the State

Facts & Procedural History

Kenneth Wayne Townsend was convicted in St. Johns County Circuit Court and sentenced. The final judgment included a $100 cost of investigation fee tha…

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Per_curiam
Per Curiam

FIFTH DISTRICT COURT OF APPEAL

STATE OF FLORIDA

_____________________________

Case No. 5D2024-1379 L.T. Case No. 2022-CF-001583 _____________________________

KENNETH WAYNE TOWNSEND,

Appellant,

v.

STATE OF FLORIDA,

Appellee. _____________________________

On appeal from the Circuit Court for St. Johns County.

R. Lee Smith, Judge.

Jonathan Edwin Mills, Orlando, for Appellant.

James Uthmeier, Attorney General, Tallahassee, and Tabitha Mills, Assistant Attorney General, Daytona Beach, for Appellee.

July 25, 2025

PER CURIAM.

In this Anders1 appeal, we affirm Kenneth Wayne Townsend’s judgment and sentence. However, the Order/Final Judgment for Charges, Costs, & Fees includes a $100.00 “Cost of Investigation to ST JOHNS COUNTY SHERIFF’S OFFICE,” pursuant to section 938.27, Florida Statutes, which the State did not request, and the

HARRIS, KILBANE, and MACIVER, JJ., concur.

_____________________________

Not final until disposition of any timely and authorized motion under Fla. R. App. P. 9.330 or 9.331. _____________________________

Footnotes
1 Anders v. California, 386 U.S. 738 (1967).
2 trial court did not orally impose. We therefore remand for the trial court to enter an amended order/final judgment for charges, costs and fees that does not include assessment of the cost of investigation. See Parks v. State, 50 Fla. L. Weekly S120, S122 (Fla. June 12, 2025) (“It is axiomatic that costs not mandated in a minimum amount set by statute will have to be requested—and established—by the State. Because they must be proven, they must be requested.”). As well, Appellant’s scoresheet adds an enhancement (i.e., sentencing multiplier) for drug trafficker, but the trial court orally ruled it was “not going to enhance for the guidelines” and it was “going to utilize the regular guidelines without the enhancement.” We further instruct the trial court to correct the scoresheet by removing the enhancement for drug trafficker. AFFIRMED and REMANDED with instructions.

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