Jourdan Daniel Parks v. State of Florida, 411 So.3d 414

The case involves whether Florida trial courts must impose statutorily mandated minimum “costs for the state attorney” on convicted persons, even if the State does not specifically request them.
Section 938.27(8), Florida Statutes (2019), requires courts to set such costs at no less than $50 for misdemeanors and $100 for felonies, with higher amounts permitted upon proof.
Jourdan Parks was convicted of multiple felonies and sentenced, with the court imposing the $100 cost for the state attorney per § 938.27(8) despite no express request from the State.
Parks challenged the imposition, arguing it was improper without a request, relying on decisions that cited § 938.27(1) and earlier caselaw.
The First District Court of Appeal upheld the imposition without a State request, creating a conflict with the Second District’s contrary ruling in D.L.J. v. State.
The Supreme Court reviewed the case to resolve this inter-District conflict on statutory interpretation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Must trial courts impose minimum state attorney costs under § 938.27(8) without State request?	State must request under § 938.27(1);	Statute § 938.27(8) is mandatory and clear,	Minimum costs are mandatory & do not require
	both subsections (1) & (8) read together	no need for request by State	a State request. Court approves Parks, disapproves D.L.J.

Parks v. State, 371 So. 3d 392 (Fla. 1st DCA 2023) (held minimum § 938.27(8) costs can be imposed without State's express request)
D.L.J. v. State, 331 So. 3d 227 (Fla. 2d DCA 2021) (held express State request was required for imposing prosecution costs, not considering § 938.27(8))
Richards v. State, 288 So. 3d 574 (Fla. 2020) (held State must request investigative costs under § 938.27(1); did not address state attorney costs in § 938.27(8))
Hills v. State, 90 So. 3d 927 (Fla. 1st DCA 2012) (recognized statutory change in 2008 made attorney costs mandatory)