DARRELL SANDERS
v.
STATE OF FLORIDA

Fla. 3d DCA | 2026-07-16
No. 2022-1470
Scales, C.J., Lobree, J., Gooden, J., Altfield, J.
2026 FL 9027 Florida District Court of Appeal, Third District (2026)

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Holding

A trial court's finding of willful and substantial probation violation is reviewed for competent, substantial evidence, and the decision to revoke probation is reviewed for abuse of discretion.


Headnotes

[1] A trial court's finding of willful and substantial probation violation is reviewed for competent, substantial evidence, while the decision to revoke probation based on su…

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Key Quotes

“The trial court's finding of a willful and substantial violation of probation term is reviewed for competent, substantial evidence. The trial court's decision to revoke probation based on such evidence is reviewed for an abuse of discretion.”

Standard of review for probation revocation decisions

Facts & Procedural History

Darrell Sanders appealed a probation revocation decision from the Circuit Court for Miami-Dade County. The trial court found Sanders committed a willf…

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Opinion of the Court

Third District Court of Appeal

State of Florida

Opinion filed July 16, 2026.

Not final until disposition of timely filed motion for rehearing.

No. 3D22-1470 Lower Tribunal No. F17-626

Darrell Sanders, Appellant,

vs.

State of Florida, Appellee.

An Appeal from the Circuit Court for Miami-Dade County, William Altfield, Judge.

Rasco Klock, and Joseph P. Klock, Jr., for appellant.

James Uthmeier, Attorney General, and David Llanes, Assistant Attorney General, for appellee.

Before SCALES, C.J., and LOBREE and GOODEN, JJ.

PER CURIAM.

Affirmed. See D.G. v. State, 315 So. 3d 72, 76 (Fla. 3d DCA 2020) ("The trial court's finding of a willful and substantial violation of probation term is reviewed for competent, substantial evidence. The trial court's decision to revoke probation based on such evidence is reviewed for an abuse of discretion.") (citation omitted); Savage v. State, 120 So. 3d 619, 621 (Fla. 2d DCA 2013) (“[W]e first assess whether the finding of a willful and substantial [probation] violation is supported by competent substantial evidence.").

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