Spiro v. State
In an Anders appeal, the Sixth DCA addressed a recognized split among Florida's district courts over whether a written cost order under section 938.15 must cite the specific local ordinance authorizing the cost. Following the Fifth DCA's reasoning in King v. State, the court held that due process is satisfied and appellate review is possible where the authority for the cost is identifiable elsewhere in the record, even without express citation in the written order. Because the plea form here identified the relevant Polk County ordinance, the court found no reversible error and affirmed.
Key facts
- Defendant Spiro was convicted and a written cost order imposing a $2 cost was entered under Florida Statute section 938.15, but the order did not cite the specific local ordinance authorizing the cost.
- The plea form identified Polk County Code 2.203 as the basis for the cost, though this ordinance was not referenced in the written cost order itself.
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Why it matters
Although arising in an Anders posture, the opinion substantively resolves a recognized inter-district conflict over cost-order specificity under section 938.15 and expressly sides with the Fourth and Fifth DCAs against… — full analysis with a trial
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