MARK GORDON ANDERSON v. STATE OF FLORIDA, 229 So. 3d 383

Anderson was convicted of lewd or lascivious molestation of a child under 12 by an adult; jury found him guilty and he was sentenced to 25 years plus lifetime sex-offender probation.
The State filed a notice to admit child hearsay under Fla. Stat. § 90.803(23); the trial court held an evidentiary hearing and issued a written order admitting the statements.
At trial the child victim testified; her out-of-court statements were also presented through three other witnesses. Defense counsel did not object contemporaneously when those witnesses testified.
Defense theory was to attack the victim’s credibility and emphasize inconsistencies in her statements.
The probation order assessed a lump-sum of $2,269 labeled "court Costs, Fees, and Fines" without a breakdown or explanation of what the assessments represented.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of repetitive child hearsay	State: child hearsay admitted under statutory exception and court’s prior ruling	Anderson: repetitive hearsay was cumulative and unfairly prejudicial under § 90.403	Not preserved for appeal because defense never objected under § 90.403; alternatively, admission within trial court’s discretion and not an abuse
Sufficiency of objections to child hearsay generally	State: prior written and evidentiary ruling admitted hearsay	Anderson: renewed objection at trial; sought exclusion	Trial court’s written order governed; renewed objection noted but specific § 90.403 objection was not made, so issue forfeited
Sentencing — failure to cite statutory authority for costs	State: need not cite statutes in written order	Anderson: order must reference statutory authority for each assessment	Court: trial court need not cite statutes, but must explain what costs represent so appellate court can identify statutory authority; lump-sum $2,269 without breakdown was improper
Remedy for improper cost assessment	State: costs valid as pronounced at sentencing	Anderson: seeks correction/remand	Remanded: conviction affirmed; probation order reversed and remanded for a breakdown of statutorily mandated costs and orally-pronounced discretionary assessments

Pardo v. State, 596 So. 2d 665 (Fla. 1992) (child hearsay under statutory exception is subject to § 90.403 balancing)
Reynolds v. State, 660 So. 2d 778 (Fla. 4th DCA 1995) (failure to preserve § 90.403 objection forfeits the argument on appeal)
Bass v. State, 35 So. 3d 43 (Fla. 1st DCA 2010) (cumulative-objection alone does not preserve § 90.403 challenge to child hearsay)
Moore v. State, 943 So. 2d 296 (Fla. 1st DCA 2006) (trial court did not abuse discretion admitting multiple witnesses to child hearsay)
Johnson v. State, 944 So. 2d 474 (Fla. 4th DCA 2006) (trial court not required to cite statutory authority for costs in written order)
Lyons v. State, 837 So. 2d 540 (Fla. 4th DCA 2003) (same)
I.B. v. State, 806 So. 2d 610 (Fla. 4th DCA 2002) (court must identify and break down costs to show statutory authority)
Sutton v. State, 635 So. 2d 1032 (Fla. 2d DCA 1994) (contrasting rule requiring statutory citation for costs)
Bradshaw v. State, 638 So. 2d 1024 (Fla. 1st DCA 1994) (improper to impose additional costs without record explanation of what they represent)
Osterhoudt v. State, 214 So. 3d 550 (Fla. 2017) (trial courts must individually pronounce discretionary fees, costs, and fines at sentencing to satisfy due process)
Jackson v. State, 983 So. 2d 562 (Fla. 2008) (challenge to costs may be preserved via Rule 3.800(b) motion)
Smith v. State, 143 So. 3d 1023 (Fla. 4th DCA 2014) (standard of review for motions to correct sentencing errors is de novo)