KEVIN PRATT
v.
STATE OF FLORIDA

Fla. 4th DCA | 2026-11-04
No. 2025-1054
Porth, J., Gross, J., May, J., Ciklin, J.
2026 FL 14868 Florida District Court of Appeal, Fourth District (2026)

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Holding

A probationer's unauthorized change of residence constitutes a willful and substantial violation of probation, and the trial court may revoke probation based on a finding of dangerousness, but must enter a written order with factual findings tied to statutory factors.


Headnotes

[1] A trial court revoking probation based on dangerousness must enter a written order containing factual findings that tie the dangerousness determination to the applicable…

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Facts & Procedural History

Pratt was on probation and changed his residence without prior approval from his probation officer. The trial court found he willfully and substantial…

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Opinion of the Court

DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA

FOURTH DISTRICT

KEVIN PRATT, Appellant,

V.

STATE OF FLORIDA, Appellee.

No. 4D2025-1054

[November 4, 2026]

Appeal from the Circuit Court for the Seventeenth Judicial Circuit, Broward County; Ari Abraham Porth, Judge; L.T. Case No. 062011CF017904A88810.

Daniel Eisinger, Public Defender, and Erika E. Follmer, Assistant Public Defender, West Palm Beach, for appellant.

James Uthmeier, Attorney General, Tallahassee, and Richard Valuntas, Senior Assistant Attorney General, West Palm Beach, for appellee.

PER CURIAM.

We affirm the trial court's finding that Pratt willfully and substantially violated probation by changing his residence without prior approval. The record supports the court's determination that Pratt posed a danger to the community. We further affirm the resulting judgment and sentence.

However, because the written danger order does not set forth factual findings tying the dangerousness determination to the applicable statutory factors, we remand for entry of a written order containing the requisite factual findings and a corrected written revocation order identifying the condition of probation violated.

Affirmed and remanded with instructions.

GROSS, MAY and CIKLIN, JJ., concur.

* * *

Not final until disposition of timely-filed motion for rehearing.


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