WATTS
v.
STATE OF FLORIDA

Fla. 1st DCA | 2026-07-01
No. 2024-2818
Robinson, J., Ray, J., Winokur, J., Treadwell, J.
2026 FL 8055 Florida District Court of Appeal, First District (2026)

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Holding

The Sixth Amendment right to trial by jury is not implicated during sentencing for violation of probation when the trial court, rather than a jury, finds the defendant to be a violent felony offender of special concern under section 948.06(8), Florida Statutes, and a danger to the community.


Headnotes

[1] The Sixth Amendment right to trial by jury does not apply to a trial court's determination that a defendant is a violent felony offender of special concern under section…

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Facts & Procedural History

Appellant Larry Watts appealed his sentencing in a probation violation case. The trial court found Watts to be a violent felony offender of special co…

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Opinion of the Court

FIRST DISTRICT COURT OF APPEAL

STATE OF FLORIDA

LARRY WATTS, Appellant,

v.

STATE OF FLORIDA, Appellee.

No. 1D2024-2818

On appeal from the Circuit Court for Escambia County. Coleman Lee Robinson, Judge.

July 1, 2026

PER CURIAM.

AFFIRMED. See Sanderson v. State, 51 Fla. L. Weekly D966 (Fla. 1st DCA May 13, 2026) (holding that the Sixth Amendment right to trial by a jury was not implicated during sentencing for violation of probation when the trial court, rather than a jury, found the defendant to be a violent felony offender of special concern under section 948.06(8), Florida Statutes, and a danger to the community).

RAY, WINOKUR, and TREADWELL, JJ., concur.


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