Gonzalez v. State
The Third DCA affirmed a probation revocation and consecutive sentencing where the entire hearing was conducted remotely via Zoom during the COVID-19 emergency, with the defendant raising no contemporaneous objection. The court held that because Rule 3.180 was temporarily suspended by the Florida Supreme Court's COVID administrative order, and because the defendant could not show the remote format deprived him of effective counsel or confrontation rights, no fundamental error occurred.
Key facts
- Defendant was charged with a probation violation and faced sentencing; the entire hearing—both the probation violation adjudication and sentencing—was conducted remotely via Zoom during the COVID-19 emergency.
- The trial court conducted the hearing while Florida Supreme Court administrative order AOSC20-23 suspended Rule 3.180, which normally governs in-person proceedings; defendant did not raise a contemporaneous objection to the remote format.
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Why it matters
This opinion extends the Third District's COVID-era remote-proceedings precedent (Clarington) to the sentencing phase of a combined VOP/sentencing hearing and aligns with the Fourth District's Brown decision, giving… — full analysis with a trial
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