Andrillon v. State
The Sixth DCA affirmed revocation of Andrillon's probation based on his commission of grand theft of a motor vehicle, carrying a concealed weapon, and violating curfew, but held the evidence was insufficient to prove he possessed burglary tools. Applying the harmless-error rationale from Romine v. State, the court still affirmed the revocation and sentence because the record showed the trial court would have revoked probation and imposed the same sentence based on the other violations alone. The court also addressed a pending Rule 3.800(b)(2) motion to correct sentencing errors, holding that because the trial court did not rule within 60 days, the motion was deemed denied by operation of law and any later-entered order granting it was a nullity, remanding for entry of a corrected order consistent with the trial court's belated ruling.
Key facts
- Andrillon was placed on probation and later charged with violating the terms through grand theft of a motor vehicle, carrying a concealed weapon, violating curfew, and possessing burglary tools.
- The trial court revoked Andrillon's probation and imposed a sentence based on these alleged violations.
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Why it matters
This opinion reinforces the Romine harmless-error doctrine for multi-ground probation revocations, confirming that an appellate finding of insufficient evidence on one violation does not automatically require reversal… — full analysis with a trial
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