Florida Statutes

Fla. Stat. § 812.025 (2025)

Charging theft and dealing in stolen property.

✓ 2025 Florida Statutes — current through the 2025 Regular Session

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812.025 Charging theft and dealing in stolen property.—Notwithstanding any other provision of law, a single indictment or information may, under proper circumstances, charge theft and dealing in stolen property in connection with one scheme or course of conduct in separate counts that may be consolidated for trial, but the trier of fact may return a guilty verdict on one or the other, but not both, of the counts.

History.—s. 9, ch. 77-342.

Notes of Decisions

Cited in 141 cases (1 in the last 5 years), 1980–2026 · leading case: Blackmon v. State, 121 So. 3d 535 (Fla. 2013).

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Blackmon v. State, 121 So. 3d 535 (Fla. 2013). · cites it 53× “§ 812.025, Fla. Stat. (2009) (emphasis added).”

Williams v. State, 121 So. 3d 524 (Fla. 2013). · cites it 56× “” § 812.025, Fla. Stat. (2008). 2 Williams was convicted of all of the charges.”

Kiss v. State, 42 So. 3d 810 (Fla. 4th DCA 2010). · cites it 44× “The charges of grand theft and dealing in stolen property were in connection with one scheme or course of conduct and, pursuant to section 812.025, Florida Statutes (2007), the state chose to charge Kiss in a single information.”

Hall v. State, 826 So. 2d 268 (Fla. 2002). · cites it 20× “On appeal, Hall claimed that the trial court erred when it adjudicated him guilty of grand theft and dealing in stolen property after accepting his plea of nolo contendere in violation of section 812.”

Jessica Patrice Anucinski v. State of Florida, 148 So. 3d 106 (Fla. 2014). · cites it 63× “” § 812.025, Fla. Stat. (2009). The question raised in this case relates to the proper remedy on appeal where a defendant has been adjudicated guilty of theft and dealing in stolen property in violation of section 812.”

Aversano v. State, 966 So. 2d 493 (Fla. 4th DCA 2007). · cites it 9× “§ 812.025, Fla. Stat. (2006) (emphasis added).”

Hall v. State, 767 So. 2d 560 (Fla. 4th DCA 2000). · cites it 11× “§ 812.025, Fla. Stat. (1997)(emphasis added).”

Toson v. State, 864 So. 2d 552 (Fla. 4th DCA 2004). · cites it 11× “Applying section 812.025, Florida Statutes (2001), we hold that there may not be two convictions, and reverse and remand for resentencing.”

Anderson v. State, 2 So. 3d 303 (Fla. 4th DCA 2008). · cites it 12× “Appellant argues that his separate convictions on one count of grand theft of various household items and two counts of dealing in stolen property, based on the same items being pawned, violates section 812.025, Florida Statutes (2005), which provides: Notwithstanding any other…”

Williams v. State, 66 So. 3d 360 (Fla. 2d DCA 2011). · cites it 8× “” § 812.025. This statute does not prevent a court from entering a judgment, which is the actual adjudication of guilt that is the condition precedent to the entry of a sentence.”

Kilmartin v. State, 848 So. 2d 1222 (Fla. 1st DCA 2003). · cites it 7× “He now appeals, contending that the trial court violated section 812.025, Florida Statutes (2001), and thereby committed fundamental error, when it entered judgments and sentences for both offenses because both were parts of "one scheme or course of conduct.”

Hudson v. State, 408 So. 2d 224 (Fla. 4th DCA 1981). · cites it 10× “In the Martin County case, defendant argues: (1) that the court erred in denying his motion to suppress evidence seized at the time of arrest; (2) that the court erred in failing to direct a judgment of acquittal based upon the theory that a co-owner of property cannot be guilty…”

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