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1st DCAOctober 9, 2024Affirmed⭐ Notable

Grigges v. State

Case No. 1D2022-4069

The First DCA affirmed a felony-murder and robbery conviction, rejecting arguments that a prospective juror's ambiguous comment about possibly knowing the defendant from the county jail constituted fundamental error, and that the trial court erred in imposing fees/costs without oral pronouncement. The court held the juror's non-committal comment caused no unfair prejudice, especially since the defendant admitted his criminal history on cross-examination, and clarified that a defendant may validly waive oral pronouncement of individualized fines and costs at sentencing if given written notice and an opportunity to be heard.

Key facts

  • Defendant was convicted of felony murder and robbery in trial court.
  • During jury selection, a prospective juror made an ambiguous comment about possibly knowing the defendant from the county jail, but was not excused; the defendant later admitted his criminal history on cross-examination.
  • +2 more key facts with a free trial

Why it matters

The most useful holding here is the clarification that a defendant can affirmatively waive oral pronouncement of discretionary fines and costs at sentencing, so long as the trial court provides notice of the total… — full analysis with a trial

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