JOSE ANGEL PATLAN
v.
THE STATE OF FLORIDA

Fla. 3d DCA | 2024-01-24
No. 2023-1879
2024 FL 782 Florida District Court of Appeal, Third District (2024) Positive Treatment

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Holding

Errors in the assessment and imposition of costs and fines are not subject to correction as illegal sentences under Florida Rule of Criminal Procedure 3.800(a).


Headnotes

[1] Procedural errors in the assessment or imposition of costs and fines in a criminal sentence are not subject to correction as illegal sentences under Florida Rule of Crimi…

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Key Quotes

“[E]rrors in the assessment of costs . . . are not subject to correction through rule 3.800(a).”

Walden v. State, 112 So. 3d 578, 580 (Fla. 4th DCA 2013)

Facts & Procedural History

Jose Angel Patlan appealed a trial court decision regarding costs and fines imposed in his criminal case in Miami-Dade County.…

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Opinion of the Court

Opinion filed January 24, 2024. Not final until disposition of timely filed motion for rehearing.

________________

No. 3D23-1879 Lower Tribunal No. F13-11161

________________

Jose Angel Patlan,

Appellant,

vs.

The State of Florida,

Appellee.

An appeal under Florida Rule of Appellate Procedure 9.141(b)(2) from the Circuit Court for Miami-Dade County, Ellen Sue Venzer, Judge. Jose Angel Patlan, in proper person. Ashley Moody, Attorney General, and Richard L. Polin, Assistant Attorney General, for appellee. Before FERNANDEZ, SCALES, and MILLER, JJ. PER CURIAM.

Affirmed. See Walden v. State, 112 So. 3d 578, 580 (Fla. 4th DCA

2013) (“[E]rrors in the assessment of costs . . . are not subject to correction through rule 3.800(a).”); Branch v. State, 322 So. 3d 209, 210 (Fla. 1st DCA

2021) (“[C]hallenges to . . . the procedure employed by the court when imposing fines and costs . . . are not challenges to an ‘illegal sentence’ correctable under rule 3.800(a).”); Blakley v. State, 746 So. 2d 1182, 1186-87 (Fla. 4th DCA 1999) (“To be illegal within the meaning of rule 3.800(a)[,] the sentence must impose a kind of punishment that no judge under the entire body of sentencing statutes could possibly inflict under any set of factual circumstances.”); see also Hoffman v. State, 413 So. 2d 150, 151 (Fla. 4th DCA 1982) (“[Florida Rules of Civil Procedure do] not apply to a criminal proceeding in a circuit court . . . [or to] appellate proceedings in the circuit court.”).


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