Edwards v. State of Florida
CourtDistrict Court of Appeal of Florida
Date FiledSeptember 9, 2026
Docket2D2025-1211
StatusPublished
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Full Opinion
DISTRICT COURT OF APPEAL OF FLORIDA
SECOND DISTRICT
JOSHUA AARON EDWARDS,
Appellant,
v.
STATE OF FLORIDA,
Appellee.
No. 2D2025-1211
September 9, 2026
Appeal from the Circuit Court for Sarasota County; Lon Arend, Judge.
Blair Allen, Public Defender, and Tosha Cohen, Assistant Public
Defender, Bartow, for Appellant.
James Uthmeier, Attorney General, Tallahassee, and William A. Leto,
Assistant Attorney General, Tampa, for Appellee.
ROTHSTEIN-YOUAKIM, Judge.
On this direct appeal of the revocation of his probation and the
sentence thereafter imposed for the underlying convictions, Joshua
Aaron Edwards argues that the trial court sentenced him pursuant to an
incorrect scoresheet. Because we conclude that the State failed to carry
its burden to establish either that certain remote prior convictions were
correctly included in his prior record or that any error resulting from
their incorrect inclusion was harmless, we reverse his sentence and
remand for further proceedings. In all other respects, the order of
revocation is affirmed.
In circuit court case no. 2020-CF-8883, Edwards entered a plea of
nolo contendere and was adjudicated guilty of possessing a controlled
substance (counts one and four), drug paraphernalia (count two), and a
firearm as a convicted felon (count three). The trial court sentenced him
on counts one, three, and four to concurrent terms of six months'
community control followed by thirty-six months' probation.1
In 2023, Edwards violated his community control by committing a
new law violation—possessing drugs again—and the trial court revoked
his community control. The court sentenced him to two years' drug
offender probation both in case no. 2020-CF-8883 and for the new law
violation in case no. 2023-CF-9846.
In 2025, however, Edwards failed to comply with the terms of his
drug offender probation. After he admitted the violation, the trial court
revoked his probation in case no. 2020-CF-8883 and sentenced him on
the two drug possession counts and the felon-in-possession count to
concurrent terms of 42.75 months' imprisonment—the lowest
permissible sentence, according to the scoresheet—followed by two years'
drug offender probation on the felon-in-possession count.
The scoresheet upon which the trial court relied identified
Edwards's felon-in-possession conviction—a second-degree felony—as
the primary offense. The scoresheet also included, in the prior record
section, a number of offenses followed by unexplained parenthetical
dates between 2003 and 2007. None of those prior offenses had been
1 The court also sentenced him to time served on count two, a first-
degree misdemeanor. Because that sentence was fully served, it was not
affected by the subsequent probation violations.
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included in the scoresheet prepared for Edwards's original sentencing in
2020.2 Those offenses added a total of 11.8 sentencing points to
Edwards's score.
After filing his notice of appeal, Edwards filed a motion under
Florida Rule of Criminal Procedure 3.800(b)(2), arguing that the newly
listed prior offenses were too remote in time to be properly included. 3
The trial court denied the motion, apparently concluding that Edwards's
2023 felony conviction for the new law violation, which he committed
after he committed the primary offense in 2020 but before he failed to
comply with the terms of his drug offender probation in 2025, permitted
the court to consider offenses that he committed more than ten years
before he committed the primary offense. It is this conclusion that
Edwards now challenges.
"The interpretation of statutes and rules of criminal procedure
present a legal question subject to a de novo standard of review." Brown
v. State, 305 So. 3d 547, 549 (Fla. 4th DCA 2020) (citing Sanders v.
State, 35 So. 3d 864, 868 (Fla. 2010). Before sentencing, every
defendant in Florida receives a scoresheet "to determine the permissible
range for the sentence that the court may impose." § 921.0024(3), Fla.
Stat. (2025); see also Fla. R. Crim. P. 3.992. The scoresheet includes a
"total offense score" based on the primary offense, any additional offenses
before the court, and victim injury. See § 921.0024(1)(a). It also
includes a "prior record score," which consists of all adult and juvenile
2 We note, however, that there is nothing inherently problematic
about that. "[A] scoresheet may be recalculated during a sentencing
upon revocation of probation to correct an omission from the original
scoresheet." Sanders v. State, 35 So. 3d 864, 869 (Fla. 2010).
3 He also filed motions under rule 3.800(a) and 3.800(c), raising
substantively the same argument in all three.
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offenses previously committed by the defendant. See id.; see also §
921.0021(5). Section 921.0021(5) defines a prior record as follows:
"Prior record" means a conviction for a crime committed by
the offender, as an adult or a juvenile, prior to the time of the
primary offense. . . . Convictions for offenses committed by the
offender more than 10 years before the primary offense are not
included in the offender's prior record if the offender has not
been convicted of any other crime for a period of 10 consecutive
years from the most recent date of release from confinement,
supervision, or sanction, whichever is later, to the date of the
primary offense.
(Emphasis added.) By its plain language, therefore, the statute would
not permit the trial court to consider, as part of Edwards's prior record,
convictions for offenses that he committed more than ten years before
the primary offense based on conviction for any other crime after the
date of the primary offense.
But that appears to be exactly what the trial court did. Although
acknowledging that Edwards's primary offense was his possession of a
firearm as a convicted felon, see § 921.0021(4) (defining "primary
offense"), which he committed on August 4, 2020, the court reasoned:
Where a court is sentencing a defendant for a violation
of community control or probation, it is the violation of
supervised release that is the "offense" then pending before
the court. See 16 Fla. Prac., Sentencing § 5:12 (West 2024-
2025 ed.). While failing to comply with the terms of probation
is not an independent criminal offense, see Shields v. State,
296 So. 3d 967, 971 (Fla. 2d DCA 2020), it is a violation of a
court order. See Carwise v. State, 449 So. 2d 943, 943 (Fla.
5th DCA 1984). Such a violation permits the court to impose
a more severe sentence on the original offense, so long as that
sentence could have been imposed when the court originally
sentenced the defendant. See Shields, 296 So. 3d at 971.
The VOP Report alleged that Defendant failed to comply with
the provisions of Drug Court, as of January 13, 2025.
Looking back from that date, Defendant had accrued his new
felony conviction in Case No. 2023-CF-9846, and other
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misdemeanor convictions not then before the Court for
sentencing. This allowed all of Defendant's prior criminal
history to be reported as part of his prior record on his
Scoresheet, unless there were offenses that were excludable
for other reasons.
(Emphasis added and footnotes omitted.) We are hard-pressed to
understand the trial court's reasoning as anything other than effectively
substituting Edwards's 2025 violation of his drug offender probation as
his primary offense and then, because he was convicted of his new law
violation less than ten years before that, concluding that all of those
assertedly too-remote convictions were correctly scored.
The State offers us no help in that regard. Rather than attempting
to elucidate or defend the trial court's reasoning, it immediately pivots to
a "tipsy coachman" basis for affirming, i.e., that Edwards's argument was
facially insufficient because he failed to identify with court records the
dates on which he was released from "confinement, supervision, or
sanction" for those prior convictions.
That would be all well and good if Edwards had only filed a rule
3.800(a) motion; the cases on which the State relies, Tyson v. State, 852
So. 2d 428, 429 (Fla. 2d DCA 2003), and McClain v. State, 157 So. 3d
528, 529 (Fla. 1st DCA 2015), both involve rule 3.800(a) motions. But he
also filed a rule 3.800(b)(2) motion, and the trial court explicitly
considered his argument in the context of rule 3.800(b)(2).
Consequently, the burden was on the State to establish that the prior
offenses were correctly included, not on Edwards to establish that they
were not. See Murphy v. State, 273 So. 3d 1147, 1147 (Fla. 2d DCA
2019) ("When the defense challenges prior convictions and the accuracy
of the scoresheet, the [S]tate has the burden of producing competent
evidence of the disputed conviction." (alteration in original) (quoting
DeGeso v. State, 771 So. 2d 1264, 1265 (Fla. 2d DCA 2000))); see also,
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e.g., Sanders v. State, 333 So. 3d 235, 235–36 (Fla. 4th DCA 2022)
("Having challenged multiple prior convictions included on his scoresheet
in his amended rule 3.800(b) motion, Appellant correctly argues that the
State was required to introduce competent evidence in support of its
scoring of Appellant's prior record and failed to do so."); Dresch v. State,
150 So. 3d 1199, 1200 (Fla. 4th DCA 2014) ("[W]e note that the State
failed to come forward with any evidence that Defendant committed two
of the prior crimes listed on his scoresheet. Defendant challenged the
inclusion of these crimes, which added 0.4 to his score, in his rule
3.800(b)(1) motion. Once contested, the State was required to provide
competent evidence that Defendant had committed these crimes.").
Because the State failed to carry its burden, we have no choice but to
conclude that those prior convictions were incorrectly included and
scored.
Moreover, we cannot conclude that the trial court's reliance on the
incorrect scoresheet was harmless. The court imposed the lowest
permissible sentence according to the scoresheet, and nothing in the
record, including the court's order denying Edwards's motion, indicates
that the court would have imposed that sentence regardless of any error
in the scoresheet. See Sanders, 35 So. 3d at 870–71 ("When a scoresheet
error is challenged on direct appeal, via a motion under Florida Rule of
Criminal Procedure 3.800(b) . . . the error 'is harmless if the record
conclusively shows that the trial court would have imposed the same
sentence using a correct scoresheet.' " (quoting Brooks v. State, 969 So.
2d 238, 241 (Fla. 2007))).
We therefore affirm the order revoking probation but reverse and
remand for resentencing.
Affirmed in part; reversed in part; remanded.
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SLEET and ATKINSON, JJ., Concur.
Opinion subject to revision prior to official publication.
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