Walker v. State
The Second District affirmed revocation of Walker's probation but reversed his VFOSC sentence because the trial court's oral comments did not match any of the statutory dangerousness factors required by section 948.06(8)(e)(1), distinguishing this case from McCray where oral findings substantially complied with the statute. The court also rejected Walker's suppression argument, holding that even assuming error in not holding a pre-VOP hearing on an identification suppression motion, any error was harmless because the victim's in-court identification rested on an independent recollection under the Crews test.
Key facts
- Walker was on probation and faced a violation of probation (VOP) hearing; the trial court revoked his probation and imposed a violent felony offender of special concern (VFOSC) sentence.
- Walker challenged the VFOSC sentence on grounds that the trial court's oral comments did not match statutory dangerousness factors required by section 948.06(8)(e)(1), and sought suppression of a victim's out-of-court identification.
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Why it matters
This opinion gives practitioners a concrete example of what does and does not satisfy the written-findings requirement for violent felony offender of special concern sentencing under section 948.06(8)(e), reinforcing… — full analysis with a trial
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