A Florida court ruled in favor of Christan Starkes, granting him the right to a certification of taxable costs after a trial court dismissed his criminal case. The decision affects Starkes, who had incurred costs while detained, and clarifies the interpretation of Florida statute 939.06 regarding discharge and acquittal in criminal cases.
The First District Court of Appeal of Florida issued its opinion on February 18, 2020, reversing the trial court's denial of Starkes' motion for certification of taxable costs. The court found that the trial court had erred in its interpretation of what constitutes a "discharge" under the statute.
Background
Christan Starkes faced multiple criminal charges, including felony Driving While License Suspended or Revoked (DWLSR). He entered plea agreements in both cases, receiving concurrent ten-year sentences to be served in the Florida Department of Corrections (DOC). However, he later filed motions to withdraw his plea agreements.
His motion to withdraw the plea for DWLSR was successful, but the trial court denied the motion for the other case, leaving the ten-year sentence intact. This led to a unique situation where Starkes remained in county jail instead of being transferred to DOC. The trial court eventually dismissed the case to return him to DOC custody, despite objections from Starkes.
After the dismissal, Starkes filed a motion seeking certification of costs incurred during his detention. He argued that the dismissal of his case constituted a discharge under Florida law, which would entitle him to a refund of costs. The trial court denied his motion, stating that the dismissal did not meet the criteria for a discharge as outlined in section 939.06 of the Florida Statutes.
The Ruling
The First District Court of Appeal reviewed the trial court's interpretation of section 939.06, which states that a defendant who is acquitted or discharged is not liable for court costs or fees while detained. The court emphasized that the language of the statute does not differentiate between reasons for discharge.
The court ruled, "The plain language of the statute requires a criminal defendant be free from cost liability when his case terminates by 'acquittal or discharge.'"
The judges, including M.K. Thomas, B.L. Thomas, and Osterhaus, agreed that the trial court had misinterpreted the statute. They clarified that a discharge occurs when charges are dropped or a case is dismissed, regardless of the reasons behind it.
In their opinion, the court stated that the trial court's reliance on a previous case, State v. Crawford, was misplaced. The Crawford case had limited the entitlement to costs to defendants who were acquitted or where the state was lax in prosecution. The First District Court of Appeal rejected this interpretation, stating that the statute does not grant the trial court discretion in determining eligibility for cost certification.
Impact
This ruling has significant implications for defendants in similar situations. It clarifies that any defendant whose case is dismissed or otherwise terminated is entitled to seek reimbursement for costs incurred during their detention. The decision also sets a precedent that the trial courts must follow the plain language of the law without imposing additional requirements or interpretations.
The ruling could lead to an increase in motions for cost certification from defendants who have had their cases dismissed or discharged, ensuring they are not unfairly burdened with costs incurred during their detention. It reinforces the principle that defendants should not bear financial responsibilities when their cases do not result in a conviction.
What's Next
The trial court must now comply with the appellate court's ruling and issue a certification of Starkes' taxable costs. While the state may have the option to appeal this decision, the court's ruling is currently in effect, and Starkes is entitled to seek reimbursement for the costs he incurred.