King v. State, 46 So. 3d 1171

Defendant pleaded no contest in 2001 to three counts of DUI with serious bodily injury and one count of DUI with property damage, receiving a composite sentence of two years' community control followed by three years' probation on the SBH counts and time-served on the property-damage count.
In 2005, the State filed violation of probation affidavits alleging violations of three probation conditions, later amended.
Defendant entered an open plea admitting to probation violations.
In 2006, the State filed a new VOP alleging arson and battery; after a VOP hearing, the trial court orally revoked probation and sentenced Defendant to 150.3 months for the 2005 and 2006 VOPs.
During appellate proceedings, Defendant moved under Rule 3.800(b) claiming the revocation order failed to include the specific violated conditions; the court granted relief on this ground and issued a written revocation order.
The issue on appeal was whether the written order sufficiently identified the probation conditions violated; the court held the order failed to specify the conditions and remanded to amend, while affirming the revocation and judgment and sentence themselves.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the revocation order must specify probation conditions violated	State argues the order is sufficient by incorporating oral findings	King contends the written order must identify specific conditions	Remanded to amend; order must specify conditions; otherwise affirmed

Delisa v. State, 910 So.2d 418 (Fla. 4th DCA 2005) (written order must identify violated probation conditions)
Defontes v. State, 889 So.2d 217 (Fla. 4th DCA 2004) (requires explicit identification of violated conditions in revocation order)
Anderson v. State, 879 So.2d 688 (Fla. 4th DCA 2004) (revocation order must specify conditions violated)
Campbell v. State, 776 So.2d 1036 (Fla. 4th DCA 2001) (prior decisions require precise specification of violated conditions)