Chambers v. State
217 So. 3d 210
Fla. Dist. Ct. App.2017Background
- A masked robber stole items from a convenience store and fled in Chambers’s vehicle; Chambers later attempted to cash a stolen lottery ticket.
- Chambers admitted being at the scene but gave changing explanations, including an initial failure to report an alleged carjacking/duress story to police.
- Chambers was convicted of robbery with a deadly weapon and sentenced to 20 years prison followed by 10 years probation; he appealed.
- At sentencing the trial court expressly cited general and specific deterrence as sentencing objectives and referenced St. Lucie County when discussing deterrence.
- The CPC scoresheet used at sentencing erroneously added 18 points for firearm possession (robbery being an enumerated felony), and the court imposed a $2,000 indigent defense-fee lien and a $50 investigative-costs charge.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence / identity of robber | State: Evidence (flight in Chambers’s car, attempt to cash stolen ticket, inconsistent statements) rebutted innocence hypothesis | Chambers: State failed to prove he was the robber; only showed presence | Court: Affirmed conviction; evidence beyond mere presence supported jury’s rejection of Chambers’s story |
| Use of deterrence / county reference at sentencing | State: Deterrence is a valid sentencing factor; court did not punish for county alone | Chambers: Sentenced more harshly because offense occurred in St. Lucie County (improper) | Court: Deterrence is permissible; court’s comment interpreted as emphasizing local deterrence policy, not an improper county-based aggravator |
| Scoresheet firearm points (18 pts) | State: Error conceded but argues harmless because sentence far above corrected minimum | Chambers: Erroneous points affected minimum and require resentencing | Court: Error not conclusively harmless; reversed and remanded for resentencing with corrected scoresheet |
| Indigent defense fees & investigative costs | State: Fee lien and costs appropriate | Chambers: Court failed to give notice/hearing for higher indigent fees; record lacks request for investigative costs | Court: Reversed fee lien above $100 for lack of notice/findings and struck $50 investigative costs because state did not request them; remand permitted to reimpose fees only after proper procedure |
Key Cases Cited
- Boyd v. State, 910 So.2d 167 (discussing jury’s role in resolving conflicting evidence)
- Charles v. State, 204 So.3d 63 (deterrence is a permissible and primary component of sentencing under the CPC)
- Andrews v. State, 207 So.3d 889 (trial court erred by sentencing based on out-of-county status)
- Norvil v. State, 191 So.3d 406 (CPC limits factors a court may consider in sentencing)
- Brooks v. State, 969 So.2d 238 (scoresheet error harmless only if record conclusively shows same sentence would be imposed)
- Somps v. State, 183 So.3d 1090 (scoresheet error not harmless despite sentence well above minimum)
- Espiet v. State, 797 So.2d 598 (erroneous scoresheet points affecting minimum require remand)
- Forbes v. State, 127 So.3d 826 (trial court must give notice/hearing before imposing indigent defense lien above statutory minimum)
- Maestas v. State, 76 So.3d 991 (procedural requirements for imposing indigent defense fees)
- Felton v. State, 939 So.2d 1159 (costs cannot be imposed absent a request or record support)
- Mills v. State, 177 So.3d 984 (court may not reimpose costs on remand if state did not request them)
- Kelly v. State, 796 So.2d 578 (error to add firearm points when the underlying offense is an enumerated felony)