Ronald J. Richards v. State of Florida, 288 So.3d 574

Ronald J. Richards pleaded nolo contendere to one count of grand theft; the trial court entered judgment including $150 in investigative costs.
The State never requested investigative costs during the trial-court proceedings.
Richards filed a motion to correct sentence arguing the court lacked authority to impose investigative costs absent a State request; the trial court denied relief.
The Fifth District reversed, ordered the investigative-costs entry stricken, but allowed the State an opportunity on remand to request investigative costs.
The Florida Supreme Court accepted review to resolve a conflict with Thomas v. State and Chambers v. State about whether the State may request investigative costs on remand.
The Court held § 938.27(1) requires the State to request investigative costs before entry of judgment; permitting a postjudgment/request-on-remand was error, so Richards was quashed in part and Thomas and Chambers were approved to the extent consistent.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a trial court can impose investigative costs when the State did not request them before judgment	Richards: Imposition was improper because § 938.27(1) requires a State request before costs may be imposed	State: The statute places no timing limit on when the request must be made	Held: A request is a prerequisite to liability and the court must include requested costs in the judgment, so the request must occur before the judgment is rendered; imposition without a pre-judgment request was error
Whether the State may request investigative costs on remand after judgment has been entered	Richards: No, the State had its opportunity and cannot get a second bite	State/Fifth DCA: The statute does not limit timing; remand can permit a later request	Held: The Fifth DCA erred in allowing a postjudgment request on remand; once a binding judgment is entered without the requested costs the opportunity has passed

Richards v. State, 258 So. 3d 576 (Fla. 5th DCA 2018) (district-court decision reversed in part; had allowed remand for State to request costs)
Thomas v. State, 236 So. 3d 1159 (Fla. 1st DCA 2018) (held State may not obtain a postjudgment request inconsistent with the statutory timing)
Chambers v. State, 217 So. 3d 210 (Fla. 4th DCA 2017) (addressed timing of investigative-cost requests under § 938.27(1))
Jackson v. State, 983 So. 2d 562 (Fla. 2008) (principle that parties generally are not entitled to a “second bite at the apple” on procedural matters)
McCloud v. State, 260 So. 3d 911 (Fla. 2018) (apply statute as written when language is clear and unambiguous)
Halifax Hosp. Med. Ctr. v. State, 278 So. 3d 545 (Fla. 2019) (statutory language must be read in context; provisions construed together)