Caison v. State, 223 So. 3d 1093

Defendant Norman Caison filed a 2016 motion under Fla. R. Crim. P. 3.800(a) challenging the procedure by which the trial court imposed $255 in court costs at his 1995 sentencing.
The costs were statutory items (total $255) composed of multiple mandatory and discretionary fees imposed by statute.
Caison argued the trial court failed to orally pronounce the costs and denied him an opportunity to contest them.
The motion asserted a procedural infirmity in sentencing rather than that the costs themselves were unauthorized or illegal.
The Third District affirmed the trial court’s denial of the 3.800(a) motion, holding the claim was not cognizable under that rule.
The court also noted Caison’s long history of at least sixteen prior appeals/original proceedings related to the same case and issued an order to show cause why he should not be barred from filing further pro se pleadings related to that matter absent counsel review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a procedural failure to orally pronounce/allow contest of court costs renders the sentence "illegal" under rule 3.800(a)	Caison: oral pronouncement and opportunity to contest were required; procedural infirmity makes sentence correctable under 3.800(a)	State: costs were statutory and not discretionary; the claim attacks procedure, not illegality of costs, and is not cognizable under 3.800(a)	Court: Claim not cognizable under rule 3.800(a); affirm denial
Whether the trial court had discretion over the amount of the challenged costs	Caison: implied error because not orally pronounced	State: amounts were statutorily mandated; no judicial discretion over amounts	Court: No discretion; costs authorized by statute
Whether repeated pro se filings warrant restrictions on future pro se filings	N/A (court-initiated concern)	N/A	Court: Ordered Caison to show cause why he should not be prohibited from further pro se filings related to the case absent attorney review; warned of sanctions if filings continue
Appropriate sanctions for continued unauthorized pro se filings	N/A	N/A	Court: Threatened refusal to accept pro se papers without counsel signature and possible sanctions including referral to DOC for disciplinary action

Jackson v. State, 983 So. 2d 562 (Fla. 2008) (distinguishing proper use of postconviction corrective procedures)
Maddox v. State, 760 So. 2d 89 (Fla. 2000) (scope of motion to correct illegal sentence under rule 3.800)
State v. Spencer, 751 So. 2d 47 (Fla. 1999) (pro se filing rights may be curtailed after abuse of process)
Hedrick v. State, 6 So. 3d 688 (Fla. 4th DCA 2010) (noting frivolous filings can obscure meritorious claims and waste resources)
Durant v. State, 177 So. 3d 995 (Fla. 5th DCA 2015) (procedural challenges to imposition of costs are not cognizable under rule 3.800(a))