QUINTON MARCUS REDDICK
v.
STATE OF FLORIDA
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A sex-offender probation violation affidavit need not be set forth with the specificity required in criminal indictments, and an apparent scrivener's error in the affidavit does not constitute a due process violation when the evidence supports the violation and both parties understood the issue.
[1] A probation violation affidavit need only allege basic facts and is not required to meet the specificity standards applicable to criminal indictments or informations.
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Join FLexlaw to unlock all legal intelligence“a VOP affidavit need only allege the basic facts and 'need not be set forth with the specificity required in criminal indictments and informations'”
Court explaining the standard for probation violation affidavits, citing Hines v. State, 358 So. 2d 183, 185 (Fla. 1978)
Reddick was sentenced to seven years of sex-offender probation in 2018 for traveling to meet a child for unlawful sexual conduct, subject to condition…
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FIRST DISTRICT COURT OF APPEAL
STATE OF FLORIDA
No. 1D2024-0612
QUINTON MARCUS REDDICK, Appellant,
V.
STATE OF FLORIDA, Appellee.
On appeal from the Circuit Court for Alachua County. James M. Colaw, Judge.
October 22, 2025
PER CURIAM.
Appellant challenges his judgment and sentence of fifteen years in prison for violating sex-offender probation. We affirm.
In 2018, an Alachua County jury found Reddick guilty of traveling to meet a child for unlawful sexual conduct. The trial court sentenced Reddick to seven years of sex-offender probation, subject to standard conditions including “you will live without violating any law." The trial court also imposed standard sexoffender conditions prohibiting “viewing, accessing, owning, or possessing any obscene, pornographic, or sexually stimulating visual or auditory material.” The court added a special condition prohibiting Reddick from accessing a “computer or [the] internet
for romantic/sexual pleasure.” Reddick transferred his sexoffender probation to Leon County.
In 2020, Reddick was arrested in Tallahassee for transmission of child pornography, and charged for that crime as well as seven counts of possession of child pornography and one count of possession with intent to promote child pornography. On appeal from an order suppressing evidence obtained in support of those charges, we reversed. See State v. Reddick, 415 So. 3d 1185 (Fla. 1st DCA 2025), rev. denied, 2025 WL 2399541 (Fla. Aug. 19, 2025). Those charges remain pending.
Based on those new charges, the State also charged Reddick with violating two conditions of his sex-offender probation. Reddick moved to suppress the evidence that generated the new charges, mirroring his arguments in the Tallahassee case. He also argued that he could not be found guilty of violating special condition 29 of his probation as alleged in his original VOP affidavit, prohibiting accessing the internet for romantic or sexual pleasure-which the trial judge hand-wrote into his earlier judgment. He relied on an apparent scrivener's error in the amended VOP affidavit, in which a successor probation officer indicated a violation of special condition 29 but used language from special condition 30, requiring a professional assessment and safety plan prior to accessing the internet.
The Alachua County court conducted an evidentiary hearing. To avoid re-victimizing the minors depicted in Reddick's child sexabuse materials, the State proceeded with the VOP using only one of the videos, which Reddick, through counsel, conceded was child pornography. The court rejected Reddick's arguments, found him guilty of violating his sex-offender probation, and sentenced him to fifteen years in prison.
Reddick raises four issues on appeal, none of which has any merit. We reversed on the suppression issues in his earlier appeal, rendering moot his first two arguments. See Reddick, 415 So. 3d at 1192-95. His argument about the VOP affidavit fails also. In context, he cannot show a due process violation in what was apparently an unintentional mistake. The evidence supported a violation of special condition 29 and the record reflects both parties
understood what was at issue. See Hines v. State, 358 So. 2d 183, 185 (Fla. 1978) (explaining a VOP affidavit need only allege the basic facts and “need not be set forth with the specificity required in criminal indictments and informations”). More importantly, the same VOP affidavit also relied on Reddick's nine violations of the standard condition of living without violating the law, as to which Reddick clearly received full due process. His final argument about costs of prosecution fails under current law. See Parks v. State, 411 So. 3d 414 (Fla. 2025).
AFFIRMED.
ROBERTS, RAY, and KELSEY, JJ., concur.