Okwor v. State
The Fourth District reversed a revocation of community control/probation because the violated conditions (curfew confinement and obeying probation officer instructions) were never orally pronounced at sentencing nor included in the written sentencing order. The court held that a probation officer's post-sentencing act of reading standard conditions to the defendant cannot substitute for the required oral pronouncement or written order.
Key facts
- Defendant Okwor was sentenced to community control/probation, with special conditions specifically announced at the plea hearing and included in the written sentencing order.
- After sentencing, a probation officer read standard conditions (including curfew confinement and obeying officer instructions) to Okwor, but these conditions were never orally pronounced by the judge at sentencing nor included in the written sentencing order.
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Why it matters
This case reaffirms the Perez/Levandoski rule that due process requires either oral pronouncement or written inclusion of probation conditions before they can support revocation, and squarely forecloses the common… — full analysis with a trial
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