Court Finds Special Probation Conditions Must Be Reasonably Related to Rehabilitation

In the case of Williams v. State of Florida, Judge Lucas with the Second District considered the validity of the lower court’s decision to order Williams not to possess or consume alcohol as a special probation condition. Sentencing courts in Florida generally have wide-ranging discretion to impose such special conditions to an individual’s probation. However, as noted by Judge Lucas, such conditions must be reasonably related to rehabilitation – if they aren’t, they are not valid.

A Look at What Happened

Williams was convicted for grand theft related to items stolen from Walmart. During the sentencing phase of his case, the trial court found Williams to be a “habitual felony offender.” He was ultimately sentenced to prison for a period of 18 months, followed by 4 years of probation.

During Williams’ sentencing hearing, arguments (and evidence) related to probation were presented, at which time the judge noted that Williams stated he was using marijuana every day, along with “cocaine and mollies” on the weekends. The judge said Williams also noted he was drinking alcohol “every other day and on the weekends.”

Beyond that statement, no other evidence was provided to the lower court as to the role (if any) alcohol actually played in Williams’ life. Still, the judge ordered Williams to pay for and participate in a drug and alcohol evaluation and, if treatment was needed, he must complete and pay for such treatment (unless waived by the court). The court further ordered “no alcohol while on probation,” which the parties assumed to mean that Williams could neither consume or possess alcohol while on probation.

Williams’ attorneys filed a motion to correct the sentencing mistake, arguing that the court erroneously imposed the special conditions on Williams’ probation. The motion was denied by the lower court which ultimately found that the conditions related to both criminal conduct, as well as conduct reasonably related to potential future criminal acts.

The Appeal Court’s Findings

In his review of the issue, Judge Lucas agreed with the overall judgment and sentencing of Williams; however, the judge reversed the lower court’s condition with respect to the prohibition of Williams using and possessing alcohol, along with the requirement to be evaluated and treated for alcohol abuse.

More specifically, Judge Lucas noted certain flaws with respect to the special conditions imposed on Williams’ probation. First, the court could not find where the facts of the case and the convictions for which Williams will serve probation were connected in any way to his consumption of alcohol. Moreover, alcohol consumption is legal for adults in the United States.

That said, the court determined that, without evidence to demonstrate the correlation between Williams’ alcohol use and his prior criminal behavior, there at least should be “some particularized evidence” to show that alcohol use would be related to future criminal acts. This case simply did not contain any such evidence and accordingly did not support the special conditions with respect to Williams’ use and possession of alcohol while on probation. Additionally, there was no demonstration that the conditions were related to Williams’ rehabilitation.

Successful completion of probation should be a top priority for all involved; however, imposing unrelated special conditions on a person’s probation may prove to be a hindrance on the individual’s ability to complete the probation as required. If you or someone you love is facing criminal charges or dealing with probation-related issues, contact one of our Bradenton criminal defense attorneys as soon as possible. Call 941-404-8919 today.

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