Alan Osterhoudt, Jr. v. State of Florida, 214 So. 3d 550

Alan Osterhoudt Jr. convicted of manslaughter with a firearm and sentenced to 30 years.
At sentencing the court imposed an aggregate lump sum of approximately $956 in fines and court costs.
The written judgment allocated $300 as a discretionary fine and a $15 surcharge, but those items were not individually pronounced orally at sentencing.
Osterhoudt filed a Rule 3.800(b) motion and appealed, arguing the court failed to individually pronounce discretionary fines/surcharges and seeking relief for sentencing error.
The Fifth District affirmed, concluding the challenge to the unpronounced discretionary fine and surcharge was unpreserved because it was a procedural challenge.
The Florida Supreme Court granted review on conflict grounds, approved the First and Second District holdings, quashed the Fifth District to the extent inconsistent, and remanded for resentencing with opportunity to reimpose after proper notice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial courts must orally pronounce discretionary fees, costs, and fines at sentencing	Osterhoudt: Failure to orally pronounce $300 discretionary fine and $15 surcharge violates due process and cannot stand	State: Challenge was procedural and unpreserved; aggregate oral pronouncement suffices	Court: Trial courts must individually pronounce discretionary fees/costs/fines at sentencing to satisfy due process; unpronounced items cannot stand without reimposition after notice

Osterhoudt v. State, 182 So. 3d 16 (Fla. 5th DCA 2015) (district-court decision at issue that affirmed sentencing despite lack of individual pronouncement)
Williams v. State, 198 So. 3d 778 (Fla. 2d DCA 2016) (held discretionary fine and surcharge must be orally pronounced or they cannot stand)
Nix v. State, 84 So. 3d 424 (Fla. 1st DCA 2012) (held discretionary costs must be orally pronounced and may be reimposed after notice and proper procedure)