State properly concedes error in Florida

2019See Walker v. State , 77 So.3d 890 (Fla. 2d DCA 2012) (error to admit evidence that an anonymous witness supplied information regarding the identity of the perpetrator); Alvarez v. State , 792 So.2d 1255 , 1257 (Fla. 3d DCA 2001) (holding that the admission of testimony relating to the contents of an anonymous tip constituted reversible error); Stribbling v. State , 778 So.2d 452 , 453-55 (Fla. 4th DCA 2001) (holding that investigating detective's testimony that he first obtained information about the perpetrator the day after the murder when he received a telephone message leaving the defenda

2019See Walker v. State , 77 So.3d 890 (Fla. 2d DCA 2012) (error to admit evidence that an anonymous witness supplied information regarding the identity of the perpetrator); Alvarez v. State , 792 So.2d 1255 , 1257 (Fla. 3d DCA 2001) (holding that the admission of testimony relating to the contents of an anonymous tip constituted reversible error); Stribbling v. State , 778 So.2d 452 , 453-55 (Fla. 4th DCA 2001) (holding that investigating detective's testimony that he first obtained information about the perpetrator the day after the murder when he received a telephone message leaving the defenda

2019See Walker v. State , 77 So.3d 890 (Fla. 2d DCA 2012) (error to admit evidence that an anonymous witness supplied information regarding the identity of the perpetrator); Alvarez v. State , 792 So.2d 1255 , 1257 (Fla. 3d DCA 2001) (holding that the admission of testimony relating to the contents of an anonymous tip constituted reversible error); Stribbling v. State , 778 So.2d 452 , 453-55 (Fla. 4th DCA 2001) (holding that investigating detective's testimony that he first obtained information about the perpetrator the day after the murder when he received a telephone message leaving the defenda

2019See Walker v. State , 77 So.3d 890 (Fla. 2d DCA 2012) (error to admit evidence that an anonymous witness supplied information regarding the identity of the perpetrator); Alvarez v. State , 792 So.2d 1255 , 1257 (Fla. 3d DCA 2001) (holding that the admission of testimony relating to the contents of an anonymous tip constituted reversible error); Stribbling v. State , 778 So.2d 452 , 453-55 (Fla. 4th DCA 2001) (holding that investigating detective's testimony that he first obtained information about the perpetrator the day after the murder when he received a telephone message leaving the defenda

2019See Dep't of Child. & Fams. v. Lotton , 172 So.3d 983 , 987 (Fla. 5th DCA 2015) ("[B]ecause there was no evidence presented to the trial court to support the findings it made, the trial court departed from the essential requirements of the law by ordering commitment.").

2019See Dep't of Child. & Fams. v. Lotton , 172 So.3d 983 , 987 (Fla. 5th DCA 2015) ("[B]ecause there was no evidence presented to the trial court to support the findings it made, the trial court departed from the essential requirements of the law by ordering commitment.").

2018See State v. Akins, 69 So. 3d 261 (Fla. 2011) (holding that HFO designation must be restated at each resentencing to be applied); Wighard v. State, 71 So. 3d 170 (Fla. 5th DCA 2011) (applying Akins and holding that HFO designation was lost when it was not restated at VOP hearing).

2012See State v. Akins, 69 So.3d 261, 269 (Fla.2011) (“[Wjhen there is a discrepancy between the written sentence and the oral pronouncement, the oral pronouncement prevails.”) (citation and internal quotations omitted).

2016See Bernier v. State, 951 So.2d 21, 22 (Fla. 2d DCA 2007) (holding that the trial court erred by finding a violation of probation when the defendant had time remaining to successfully complete a mandatory course).

2016See Bernier v. State, 951 So. 2d 21, 22 (Fla. 2d DCA 2007) (holding that the trial court erred by finding a violation of probation when the defendant had time remaining to successfully complete a mandatory course).

2011See A.M. v. State, 958 So.2d 461 (Fla. 2d DCA 2007).

2011See A.M. v. State, 958 So.2d 461 (Fla. 2d DCA 2007).

1999See State v. Boyd, 717 So.2d 524 , 525 (Fla.1998); Tatum v. State, 24 Fla. L.

1999See State v. Boyd, 717 So.2d 524 (Fla.1998), approving, 699 So.2d 295 (Fla. 1st DCA 1997); Tatum v. State, 24 Fla. L.

1995Tripp v. State, 622 So.2d 941, 942 (Fla. 1993) (“if a trial court imposes a term of probation on one offense consecutive to a sentence of incarceration on another offense, credit for time served on the first offense must be awarded on the sentence imposed after revocation of probation on the second offense”).

1995As the state properly concedes error, the sentences are REVERSED and this cause is REMANDED for resen-tencing in accordance with the guidelines set forth by the supreme court in Tripp v. State, 622 So.2d 941 (Fla.1993).

1997State v. Brown, 633 So.2d 1059 (Fla.1994); Cleveland v. State, 587 So.2d 1145 (Fla.1991).

1995See Brown v. State, 617 So.2d 744, 747 (Fla. 1st DCA 1993) (stating that defendant may not be convicted and sentenced to both possession of a firearm during the commission of a felony and armed robbery with a firearm where both crimes occurred during the same criminal transaction), approved, 633 So.2d 1059 (Fla.1994).

2026See State v. T.G., 800 So. 2d 204, 212 (Fla. 2001); J.R. v. State, 992 So. 2d 876, 876 (Fla. 5th DCA 2008); K.E.N. v. State, 892 So. 2d 1176, 1179 (Fla. 5th DCA 2005); M.Q. v. State, 818 So. 2d 615, 618 (Fla. 5th DCA 2002).

2026See State v. T.G., 800 So. 2d 204, 212 (Fla. 2001); J.R. v. State, 992 So. 2d 876, 876 (Fla. 5th DCA 2008); K.E.N. v. State, 892 So. 2d 1176, 1179 (Fla. 5th DCA 2005); M.Q. v. State, 818 So. 2d 615, 618 (Fla. 5th DCA 2002).

2026As to sentencing, the State properly concedes error regarding certain costs because “a court’s oral pronouncement of a sentence controls over the written sentencing document.” Williams v. State, 957 So. 2d 600, 603 (Fla. 2007).

2026See State v. T.G., 800 So. 2d 204, 212 (Fla. 2001); J.R. v. State, 992 So. 2d 876, 876 (Fla. 5th DCA 2008); K.E.N. v. State, 892 So. 2d 1176, 1179 (Fla. 5th DCA 2005); M.Q. v. State, 818 So. 2d 615, 618 (Fla. 5th DCA 2002).

2026See State v. T.G., 800 So. 2d 204, 212 (Fla. 2001); J.R. v. State, 992 So. 2d 876, 876 (Fla. 5th DCA 2008); K.E.N. v. State, 892 So. 2d 1176, 1179 (Fla. 5th DCA 2005); M.Q. v. State, 818 So. 2d 615, 618 (Fla. 5th DCA 2002).

2025In Williams v. State, 927 So. 2d 145, 146 (Fla. 1st DCA 2006), this Court held that double jeopardy precluded the defendant’s dual convictions and sentences where both burglary charges arose from a single entry of the dwelling and involved only one victim.

2024Competency determinations and the specific procedures outlined in Florida Rules of Criminal Procedure 3.210–3.212 “safeguard a defendant’s due process right to a fair trial and to provide the reviewing court with an adequate record on appeal.” Dougherty v. State, 149 So. 3d 672, 676 (Fla. 2014). “[O]nce a trial court has reasonable grounds to believe that a criminal defendant is not competent to proceed, [the trial court] has no choice but to conduct a competency hearing.” Monte v. State, 51 So. 3d 1196, 1202 (Fla. 4th DCA 2011).

2024Competency determinations and the specific procedures outlined in Florida Rules of Criminal Procedure 3.210–3.212 “safeguard a defendant’s due process right to a fair trial and to provide the reviewing court with an adequate record on appeal.” Dougherty v. State, 149 So. 3d 672, 676 (Fla. 2014). “[O]nce a trial court has reasonable grounds to believe that a criminal defendant is not competent to proceed, [the trial court] has no choice but to conduct a competency hearing.” Monte v. State, 51 So. 3d 1196, 1202 (Fla. 4th DCA 2011).

2020See McCraney v. State, 207 So. 3d 1023, 1023 (Fla. 5th DCA 2017) (“[A] judgment 1 The appellant pled open to the court. adjudicating a defendant guilty of an offense to which he or she did not plead constitutes fundamental error.”).

2019See Sainvil v. State, 248 So. 3d 148, 149 (Fla. 4th DCA 2018) (“The imposition of restitution without notice or a hearing is error.”) (citation omitted).

2018See, e.g., Smith v. State, 143 So. 3d 1023, 1024-25 (Fla. 4th DCA 2014) (“When a defendant violates his youthful offender probation by committing a substantive violation, the court is not bound to the usual youthful offender sentence of six years or less and can impose up to the statutory maximum for the underlying offenses.

2017See Williams v. State, 186 So.3d 989, 993 (Fla. 2016) (holding that consecutive sentences of mandatory minimum terms for multiple firearm offenses are impermissible if the offenses arose from the same criminal episode and the firearm was not discharged).

2017See Rosado v. State, 129 So.3d 1104, 1107 (Fla. 5th DCA 2013).

2017See Brady v. State, 65 So.3d 599, 602 (Fla. 5th DCA 2011) (holding that reclassification was not proper where the trial court instructed the jury on both forms of aggravated battery and the jury returned a verdict of guilty as charged).

2017“The issue of ‘[wjhether the circuit court fundamentally erred in failing to hold a competency hearing presents a pure question of law subject to de novo review.’ ” Baker v. State, 221 So.3d 637, 639 (Fla. 4th DCA 2017) (quoting A.L.Y. v. State, 212 So.3d 399, 402 (Fla. 4th DCA 2017)).