Perez v. State
Defendant convicted of animal confinement offenses challenged restitution awarded to Levy County Animal Services (LCAS) for the cost of caring for seized dogs, and a $50 investigative cost imposed without State request. The First DCA held LCAS was not a 'direct victim' under section 775.089(1)(c)1 because it merely provided public services (animal care) in response to the crime, and struck the unrequested $50 investigative cost.
Key facts
- Defendant was convicted of animal confinement offenses; Levy County Animal Services incurred costs caring for seized dogs during prosecution.
- Trial court awarded restitution to LCAS for animal care costs and imposed a $50 investigative cost without State request.
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Why it matters
This decision extends the Fourth District's Anglin/Lucas framework distinguishing 'direct victims' from entities providing public services in response to crime, applying it for the first time to animal control agencies… — full analysis with a trial
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