CASTRO v. STATE (2025)

Appellant Onelio Castro appeals from the trial court's revocation of his probation. Following a probation violation hearing, the court revoked Castro's probation and sentenced him to sixty years in prison. The court did not issue a written opinion revoking Castro's probation. “The United States Supreme Court has stated that the due process requirements of a probation revocation hearing include ․ a written statement by the factfinder as to the evidence relied on and the reasons for revoking probation.” McCloud v. State, 653 So. 2d 453, 454–55 (Fla. 3d DCA 1995) (quoting with emphasis Black v. Romano, 471 U.S. 606, 612, 105 S.Ct. 2254, 85 L.Ed.2d 636 (1985)). “It is well-settled that a trial court must ‘reduce to writing its oral pronouncement of the violations and revocation of ․ probation.’ ” Mitchell v. State, 238 So. 3d 386, 386 (Fla. 3d DCA 2018) (quoting Brown v. State, 127 So. 3d 831, 831 (Fla. 3d DCA 2013)).

Both Castro and the State properly agree that we must remand with instructions to enter a written order. Accordingly, we remand for the trial court to enter a written order of revocation of probation.¹

Remanded with instructions.

FOOTNOTES

1.   We express no opinion on any of the other issues raised.

LINDSEY, J.