ADRIAN WOOD
v.
STATE OF FLORIDA
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Adrian Wood appealed his conviction for fleeing law enforcement and driving with a suspended license, raising three issues including a challenge to the trial court's denial of a motion for judgment of acquittal, rejection of a mental health defense, and imposition of a $100 cost of prosecution. The Florida Court of Appeal affirmed the judgment and sentence on all three issues, finding the cost of prosecution was properly imposed as a mandatory charge under state law.
The trial court did not err in denying the motion for judgment of acquittal or in preventing the mental health defense. The trial court properly imposed the $100 cost of prosecution as a mandatory cost under state law that does not require a prior request from the State Attorney.
[1] A $100 cost of prosecution is a mandatory minimum cost under statute and may be imposed without a prior request from the state attorney, distinguishing it from investigat…
Previewing 1 of 1 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“the [$100] cost for the state attorney is a minimum cost that is mandated by subsection (8) and not an 'investigative' cost incurred by an agency, as described in § 938.27(1), which can only be imposed 'if requested' by the agency”
The court explained the legal distinction between mandatory prosecution costs and discretionary investigative costs, establishing that the $100 cost does not require a prior State Attorney request.
Previewing 1 of 2 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceAdrian Wood was convicted of one count of fleeing or attempting to elude law enforcement and one count of driving with a suspended license. At sentenc…
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Adrian James Wood appeals his judgment and sentence for one count of fleeing or attempting to elude law enforcement and one count of driving with a suspended license. Wood presents three issues for our review: (i) whether the trial court erred by denying Wood’s motion for judgment of acquittal; (ii) whether the trial court erred by preventing Wood from raising a mental health defense; and (iii) whether the trial court erred by imposing a $100 cost of prosecution.
As for the first two issues, we affirm the trial court’s decision without further comment. As for the third issue, Wood argues that the trial court erred by imposing a $100 cost of prosecution without first receiving a request from the State. This Court has recently
explained that “the [$100] cost for the state attorney is a minimum cost that is mandated by subsection (8) and not an ‘investigative’ cost incurred by an agency, as described in § 938.27(1), which can only be imposed ‘if requested’ by the agency.” Parks v. State, 371 So. 3d 392, 392–93 (Fla. 1st DCA 2023), review granted, SC2023-1355, 2024 WL 370043 (Fla. Jan. 31, 2024). Thus, the trial court properly imposed the cost of prosecution.
We therefore AFFIRM Appellant’s judgment and sentence. OSTERHAUS, C.J., and BILBREY and NORDBY, JJ., concur.
_____________________________ Not final until disposition of any timely and authorized motion under Fla. R. App. P. 9.330 or 9.331.