State v. Washington
The Sixth DCA affirmed dismissal of an Office of Statewide Prosecution (OSP) information charging Peter Washington with illegal voting, holding that OSP lacked jurisdiction because his offense of casting an illegal ballot occurred entirely within a single judicial circuit (Orange County), despite the fact that his voter registration and vote were later electronically transmitted to Leon County for processing. The court held that a crime 'occurs' for OSP jurisdictional purposes only where the acts constituting the offense are committed, not wherever downstream administrative processing takes place, and that the State failed to preserve an argument based on a newly effective 2023 statutory amendment expanding OSP's 'effects jurisdiction' because it never sought leave to amend or moved for reconsideration below. The court expressly certified conflict with the Third DCA's Miller and Fourth DCA's Hubbard decisions, which had reached the opposite conclusion on nearly identical facts.
Key facts
- Peter Washington was charged by the Office of Statewide Prosecution with illegal voting for casting a ballot in Orange County; his voter registration information was subsequently transmitted electronically to Leon County for processing.
- The trial court dismissed the information for lack of jurisdiction; the State appealed.
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Why it matters
This is a significant, certified-conflict opinion resolving a live and recurring issue in Florida election-fraud prosecutions: whether the Office of Statewide Prosecution has jurisdiction to charge single-circuit… — full analysis with a trial
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