Fraser v. State of Florida

CourtDistrict Court of Appeal of Florida
DecidedJune 10, 2026
Docket1D2024-2317
StatusPublished

This text of Fraser v. State of Florida (Fraser v. State of Florida) is published on Counsel Stack Legal Research, covering District Court of Appeal of Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fraser v. State of Florida, (Fla. Ct. App. 2026).

Opinion

FIRST DISTRICT COURT OF APPEAL STATE OF FLORIDA _____________________________

No. 1D2024-2317 _____________________________

ENOCH NATHANIEL FRASER III,

Appellant,

v.

STATE OF FLORIDA,

Appellee. _____________________________

On appeal from the Circuit Court for Baker County. Phillip A. Pena, Judge.

June 10, 2026

NEFF, J.

Appellant Enoch Nathaniel Fraser III appeals his judgment and sentence following a jury trial on multiple counts, including two counts of tampering with a witness (Counts VII and VIII). He raises three issues on appeal. As to issue one, we affirm his conviction on Count VIII for tampering with witness Kim Beverly without further discussion, as the credibility and weight of the evidence presented through the recorded jail calls was a matter within the exclusive province of the jury to resolve. Tibbs v. State, 397 So. 2d 1120, 1123 (Fla. 1981). We write to address two asserted sentencing errors: whether the information’s failure to allege an essential element of the tampering offense precluded the trial court from imposing first-degree felony sentences on Counts VII and VIII, and whether the written probation order improperly included a special condition not orally pronounced at sentencing.

I. First-Degree Felony Sentences on Counts Charged as Third-Degree Felonies

In the initial issue we address, the Appellant challenges his sentences on Counts VII and VIII on two grounds. First, he argues the sentences imposed exceeded the five-year statutory maximum applicable to third-degree felonies. Second, he argues the trial court compounded that error by retroactively elevating the degree of his convictions from third-degree to first-degree felonies in the written judgment after he raised the issue in a motion to correct sentencing error. We disagree as to each ground and affirm.

A. Pertinent Facts

The Second Amended Information charged Counts VII and VIII as third-degree felonies under section 914.22(1)(e), Florida Statutes. The information did not allege the degree of the offense involved in the underlying official proceeding in which the witness tampering occurred. Both counts stated “F3/L4” indicating they were each charged as third-degree felonies.

On the weekend prior to the start of the jury trial, defense counsel independently identified during trial preparation that the tampering counts might be subject to reclassification as first- degree felonies. Defense counsel contacted the State to confirm this understanding and also informed the Appellant. When trial commenced the following Monday, defense counsel raised the issue on the record before the jury was brought in or sworn. The State agreed, noting that because Count I charged a second-degree felony, the tampering counts would constitute first-degree felonies under section 914.22(2)(c) and Rule 3.704, Fla. R. Crim. P. Both parties confirmed this understanding to the trial court. The Appellant was present throughout this discussion. The scoresheet was revised accordingly, and the court then took a short recess to allow defense counsel to review the revised scoresheet with the Appellant.

2 When the court went back on the record after the break, the court conducted a colloquy with the Appellant. The Appellant was advised that if convicted on the tampering counts as first-degree felonies, he faced a minimum guidelines sentence of 120.6 months, a maximum sentence of 95 years, and, if found to be a habitual felony offender, a potential sentence of life imprisonment. The end of the colloquy went as follows:

THE COURT: This is now, I’m being told, if you’re found responsible, it could be a first-degree felony or would be a first-degree felony depending on their finding, and that that would, based on the HFO status, that you could be sentenced to life imprisonment. Do you understand that? MR. FRASER: Yes, sir. THE COURT: All right. So it just sounds to me, just so the record is clear, that it doesn’t really matter what the offer is or what the potential sentence is, that you would like to move forward. MR. FRASER: If I’m found guilty, I’ll be comfortable with never getting out. I’m not guilty, so I’m going to take my chances on this. THE COURT: Okay. That’s fine. I want to make sure that we’re on the same page and that you feel comfortable with your decision. MR. FRASER: Yes, sir.

As is evident from the trial transcript, the Appellant confirmed his understanding of the charges and the potential sentence if found guilty. He then elected to proceed to trial without reservation.

At the charge conference, defense counsel requested the jury be given an interrogatory asking it to determine the degree of the underlying offense affected by the tampering, thereby implementing the first-degree felony framework. No objection was made to the jury instructions for Counts VII and VIII. The jury returned verdicts of guilty as charged on both counts and made special findings through the interrogatory that the tampering involved the investigation or prosecution of both a second and third-degree felony.

3 The trial court sentenced the Appellant to ten years of probation on Count VII and fifteen years in prison on Count VIII. These sentences were consistent with first-degree felony treatment under section 914.22(2)(c). The written judgment, however, initially adjudicated the Appellant guilty of third-degree felonies on Counts VII and VIII, consistent with the face of the Second Amended Information. Defense counsel acknowledged the first-degree felony classification of these counts at sentencing without objection.

Appellant subsequently filed a motion to correct sentencing error under Rule 3.800(b)(2), Fla. R. Crim. P., arguing the sentences exceeded the five-year statutory maximum for third- degree felonies. In response, the trial court denied the motion and amended the written judgment to reflect first-degree felony adjudications on Counts VII and VIII.

B. Analysis

At the outset, we acknowledge that the Second Amended Information failed to allege the third element of the tampering offense as required by section 914.22 and as reflected in the standard jury instruction. Specifically missing from that document is the degree of the underlying official proceeding affected by the tampering, which determines the degree of the offense. Fla. Std. Jury Instr. (Crim.) 21.10. This omission is not trivial. Element three is expressly identified in the statute and the standard jury instruction as a required element the State must prove beyond a reasonable doubt, and the category of underlying proceeding directly determines the level of the felony the tampering constitutes. See, e.g., Pickett v. State, 109 So. 3d 841, 844–45 (Fla. 3d DCA 2013). As the Appellant points out, it is fundamental error to convict a defendant of a felony that is not charged. Jaimes v. State, 51 So. 3d 445, 451 (Fla. 2010). “An information must allege each of the essential elements of a crime to be valid.” State v. Dye, 346 So. 2d 538, 541 (Fla. 1977). “No essential element should be left to inference.” Id. See also Cochenet v. State, 445 So. 2d 398, 399 (Fla. 5th DCA 1984) (“As the appellant argues in his brief, the amended information charged Cochenet entered the trailer with the intent to commit aggravated assault; it did not allege that the assault actually occurred. Although the fact of the assault is

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Related

State v. Anderson
537 So. 2d 1373 (Supreme Court of Florida, 1989)
Cochenet v. State
445 So. 2d 398 (District Court of Appeal of Florida, 1984)
Tibbs v. State
397 So. 2d 1120 (Supreme Court of Florida, 1981)
State v. Dye
346 So. 2d 538 (Supreme Court of Florida, 1977)
Jackson v. State
33 Fla. L. Weekly Fed. S 357 (Supreme Court of Florida, 2008)
Jaimes v. State
51 So. 3d 445 (Supreme Court of Florida, 2010)
Pickett v. State
109 So. 3d 841 (District Court of Appeal of Florida, 2013)

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Fraser v. State of Florida, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fraser-v-state-of-florida-fladistctapp-2026.