Greene v. State
The Third DCA affirmed a PRR sentence imposed after a probation violation, holding that the defendant's own sworn testimony at the VOP hearing establishing his release date from prison was sufficient evidence to prove PRR eligibility, distinguishing cases where PRR status was based only on hearsay or unadmitted sentencing records. However, the court reversed and remanded because the written probation revocation order failed to specify the evidence relied upon and the reasons for revocation, as required by due process.
Key facts
- Greene was on probation and the State filed a violation of probation (VOP) charge, alleging facts that would make him eligible for a Prison Release Reoffender (PRR) enhancement.
- At the VOP hearing, Greene testified under oath about his release date from a state correctional facility; the trial court revoked his probation and imposed a PRR sentence.
- +2 more key facts with a free trial
Why it matters
This opinion gives prosecutors a clear, low-burden method to prove PRR release dates through the defendant's own testimony rather than relying on business records or sentencing packets that must be formally admitted… — full analysis with a trial
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