STEVEN SANFORD
v.
STATE OF FLORIDA

Fla. 5th DCA | 2026-08-07
No. 2025-3908
Cotton, J., Harris, J., Soud, J., MacIver, J.
2026 FL 10122 Florida District Court of Appeal, Fifth District (2026)

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Holding

When a trial court revokes a defendant's probation, it must render a written order identifying the specific conditions of probation that were violated.


Headnotes

[1] When a trial court revokes a defendant's probation, it must enter a written order identifying the specific conditions of probation that were violated, even if the defenda…

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Key Quotes

“If a trial court revokes a defendant's probation, the court is required to render a written order noting the specific conditions of probation that were violated.”

Court stating the legal requirement for probation revocation orders

Facts & Procedural History

Steven Sanford entered an open plea and admission in two county court cases—a new law violation and a violation of probation. Sanford admitted to viol…

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Opinion of the Court

FIFTH DISTRICT COURT OF APPEAL

STATE OF FLORIDA

Case No. 5D2025-3908 LT Case Nos. 2025-MM-002749-A 2025-MM-006944-A

STEVEN SANFORD, Appellant,

V.

STATE OF FLORIDA, Appellee.

On appeal from the County Court for Marion County. Lori Cotton, Judge.

Matthew J. Metz, Public Defender, and George D.E. Burden, Assistant Public Defender, Daytona Beach, for Appellant.

James Uthmeier, Attorney General, Tallahassee, and Stephen R. Putnam, Jr., Assistant Attorney General, Daytona Beach, for Appellee.

August 7, 2026

HARRIS, J.

Appellant, Steven Sanford, appeals his judgments and sentences imposed in two county court cases (a new law violation and a violation of probation (VOP)) following entry of an open plea

and admission. Sanford did not reserve the right to appeal the denial of a legally dispositive issue, and he did not move to withdraw his plea or admission and his sentences are legal. However, there is no written order revoking probation identifying the conditions Sanford admitted to violating. “If a trial court revokes a defendant's probation, the court is required to render a written order noting the specific conditions of probation that were violated." See Patt v. State, 876 So. 2d 1278 (Fla. 5th DCA 2004); Brinson v. State, 866 So. 2d 1268, 1269 (Fla. 5th DCA 2004). Sanford admitted to violating the four conditions listed in the VOP affidavit, and the court accepted the admission. Accordingly, we affirm the judgments and sentences in both cases, but remand the VOP case (2025-MM-002749-A) for the entry of an order identifying the conditions of probation Sanford violated. Patt, 876 So. 2d at 1278.

AFFIRMED and REMANDED with instructions.

SOUD, and MACIVER, JJ., concur.


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