# Petition — Leavitt v. Florida

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## Record

- **Collection:** Supreme Court brief
- **Document type:** Petition
- **Published:** January 1, 1979
- **Citation:** 444 U.S. 839

## Text

F
JUN 14 4079 |
'
ae JR., CLERK

ee eS

IN THE

Supreme Court of the Anited States

No.
48-1860
BRANDON H. LEAVITT,
Petitioner,
v.
STATE OF FLORIDA,
Respondent.

PETITION FOR WRIT OF CERTIORARI

SELIG I. GOLDIN
Goldin & Cates
Post Office Box 1251
Gainesville, Florida 32602
(904) 378-1673

Attorneys for Petitioner

LS ENN TTT
Washington, D.C. e CLB PUBLISHERS e LAW PRINTING CO. e (202) 393-0625

ee ee

(i)
TABLE OF CONTENTS

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CONSTITUTIONAL PROVISION INVOLVED ...........3
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TABLE OF AUTHORITIES ee IN THE

Cine Page | Supreme Court of the United States
United States v. Dalpiaz, 494 F.2d 374 2.1... cee ee eee 7
United States v. Davis, 482 F.2d 893 (1973) .......... 79
United States v. Edwards, 498 F.2d 496 (1974) .......... 6 No.
United States v. Freeland, 562 F.2d 383 (1977) .......... 8
United States v. Homburg, 546 F.2d 1350 (C.C.A. |

Carne <2 ct oe Wiehe Saree te bbe eek) 0b ae Ol 8 | BRANDON H. LEAVITT,
United States v. Meulener, 351 F. Supp. 1284 (C.D. Piette

i a Se Seid a tae a cin dig: ein h b.b-O¥ 7 ;

v.
United States v. Skipwith, 482 F.2d 1272 (1973) ......... 6
United States v. Williams, 516 F.2d 11 (1975) ........... 6
agen STATE OF FLORIDA,

4th Amendment to the U.S. Constitution .............6.. 3 ‘ i
14th Amendment to the U.S. Constitution ............-. 3 espondent.
See: Deere PO a, Ss kas Casas wee cen ob 2

PETITION FOR WRIT OF CERTIORARI

Petitioner, BRANDON H. LEAVITT, prays that a
Writ of Certiorari be issued to review the Judgment of
| the District Court of Appeal, First District of Florida,
entered on 17 April 1979, Rehearing denied 15 May
1979. (Said Judgment and Order is incorporated as

Appendix “A’’).
The Circuit Court, Eighth Judicial Circuit, in and for
Alachua County, Florida, entered a Judgment on the
7th day of August 1978, sentencing Petitioner to 5
| years probation with an adjudication of guilt withheld
for possession of cocaine. As a special condition of
probation, Petitioner was required to serve | year in

custody. Petitioner was also placed upon a concurrent
probation with an adjudication of guilt withheld for a
period of 3 years for possession of more than 5 grams
of cannabis. (Said Judgment is incorporated as
Appendix “B”).

The District Court of Appeal, First District, rendered
its decision and opinion wherein it affirmed the
Judgment as to the cocaine offense; however, the
Judgment as to the cannabis offense was reversed and
the cause remanded for further disposition on the lesser
included misdemeanor offense of possession of less than
5 grams of cannabis. This decision is not yet reported
in the Southern Reporter System. (This opinion is
incorporated as Appendix ‘‘A’’).

Under the Florida appellate system, this decision is a
Judgment of last resort in the State of Florida.

The stage of the proceedings in which the Federal
question sought to be reviewed was first raised were:
(1) in the Trial Court by pre-trial Motion to Suppress
Evidence; and (2) at the Appellate level, First District
Court of Appeal, by Point One of Petitioner’s Brief.

Thereafter, Petitioner filed his request for a Stay
pending disposition of this Petition for Writ of
Certiorari.

STATEMENT OF JURISDICTION

The jurisdiction of this Court is invoked under
Section 1257(3), Title 28, U.S.C.

ee eee

QUESTION PRESENTED

The Federal Question raised in this Petition is:

WHETHER AN INDIVIDUAL WHO SUBMITS
HIMSELF FOR PREBOARDING INSPECTION
PURSUANT TO FEDERAL ANTI-HIJACKING
PROCEDURES AT AN AIRPORT CAN WITH-
DRAW AND WITHDRAW CONSENT TO A
SEARCH OF CARRY ON PERSONALTY.

CONSTITUTIONAL PROVISION INVOLVED

This case presents questions concerning the construc-
tion and interpretation of the 4th and 14th Amend-
ments to the United States Constitution, which provide:

4th: “The right of the people to be secure in their
persons, * * * effects, against unreasonable searches
and seizures, shall not be violated * * * *.”

14th: “***nor shall any state deprive any
person of life, liberty, or property, without due
process of law. * * * *”

STATEMENT

Petitioner was arrested and charged with a number of
offenses on 8 December 1977. After various Informa-
tions were filed, a pre-trial Motion to Suppress Evidence
was filed alleging that the search of Petitioner at the
Gainesville, Florida Airport during a_ preboarding
screening procedure was illegal. This Motion was denied
and the trial of this cause began before a jury on 25
May 1978. The jury found Peutioner guilty of

4

possession of cocaine and possession of more than 5
grams of cannabis.
Petitioner’s Motion for New Trial was denied and the

District Court of Appeal, First District of Florida, heard

the appeal as stated herein.

The events, sufficient for an understanding of the
facts leading to Petitioner’s conviction, are as follows:

On 8 December 1977 at the Gainesville, Florida
Airport, Petitioner began to go through the pre-
boarding screening process as he prepared to board a
flight. When a carry-on bag went through the X-Ray
machine, the attendant noticed that there was an object
she could not identify. The attendant testified that
Petitioner pushed the bag toward her for inspection and
while the inspection was in progress, he changed his
mind. Another attendant confirmed that Petitioner did
not want to complete the inspection process and that
the first attendant gave Petitioner an option to leave
the inspection area. Petitioner testified that he did not
consent to a search of his bag. As he left the inspection
area, he left a toilet kit which the first attendant
handed to a nearby police officer. She stated that she
did not see any controlled substance in the toilet kit.
The police officer testified that the toilet kit was open
and he saw cannabis and a white powder inside of it.

The police officer chased Petitioner and, after
shooting him in the foot, Petitioner was placed under
arrest and this prosecution ensued.

SUMMARY OF ARGUMENT

If an individual has the right to withdraw from a
pre-boarding screening area of an airport, he also has
the right to object to a search of his personal property.
The attendant continued her search after the consent
was withdrawn and it is therefore Petitioner’s position
that the search and subsequent seizure was violative of
constitutional limitations.

ARGUMENT

In recent years, this Country, as well as the rest of
the world, has been plagued by a new criminal element
comprised of individuals who hijack commercial air-
craft. Because of the great danger to the innocent
passengers and airline personnel from armed wackos, it
has become necessary to search all passengers for
weapons. As a result, the passenger boarding an airliner
has now been asked to submit to a search and, as
would be expected, these searches have uncovered
numerous folks carrying all types of illegal substances
which are not weapons. Thus, a whole new body of law
is evolving concerning airport searches. It is not
Petitioner’s purpose to contest the validity or rationale
of these procedures; rather, Petitioner will attempt to
demonstrate to this Court that within the parameters of
the applicable law, the search of Petitioner was an
illegal act.

In the context of this case, the Petitioner was not
considered as a risk because of any actions on his part
before he began the screening process and the X-Ray

machine, sometimes called a magnetometer, could not
be utilized to identify an object in his carry-on bag.
Under similar factual situations, two results have
emerged from the Federal Court -ystem. On one side is
the rule of the United States Court of Appeals, Fifth
Circuit, which is personified by the decision in United
States v. Skipwith, 482 F.2d 1272 (1973). In this case,
the Defendant presented himself for boarding and the
ticket agent detained him since he fit an anti-skyjack
profile. He was searched and a controlled substance was
found. The “ourt first noted that:

‘**... Rather, Skipwith came to the specific part of
the airport where he knew or should have known
all citizens were subject to being searched.”

The Court then stated the rule as:

‘“..we hold that those who actually present

themselves for boarding on an air carrier, like

those seeking entrance into the country, are
subject to a search based on mere or unsupported
suspicion,”

This is in line with the holdings of the United States
Court of Appeals, Second Circuit, in United States v.
Edwards, 498 F.2d 496 (1974), and United States v.
Williams, 516 F.2d 11 (1975) that:

“... we hold that there was implied consent to

search the carry-on baggage by virtue of the fact

that baggage which one does not want to have
searched may be consigned to the baggage
compartment.”

The effect of this line of cases is that once this
implied consent is given by the act of entering a
boarding area, any suspicious act, whether in person or
an unidentified object while baggage is going through a

magnetometer, justifies a search and consent can not be
withdrawn at that point.

The other rule that emerged first was enunciated in
United States v. Meulener, 351 F. Supp. 1284 (C.D.
Cal., 1972), in which the search of a passenger’s
suitcase was held invalid because the passenger was not
given the option to decline a search upon the condition
that he not board the aircraft.

In United States v. Davis, 482 F.2d 893 (1973), the
United States Court of Appeals, Ninth Circuit, had an
opportunity to review this issue. As Davis approached
the loading gate, he was told that a routine security
check was necessary and the agent reached for Davis’
briefcase, opened it, found a gun and he was taken into
custody. In reviewing the applicable law, the Court
stated:

“.,. Searches conducted as a part of a general
regulatory scheme in furtherance of an administra-
tive purpose, rather than as part of a criminal
investigation to secure evidence of crime, may be
permissible under the Fourth Amendment though
not supported by a showing of probable cause
directed to a particular place or person to be
searched.”

The Court then held:

“In sum, airport screening searches of the persons
and immediate possessions of potential passengers
for weapons and explosives are reasonable under
the Fourth Amendment provided each prospective
boarder retains the right to leave rather than
submit to the search.”’ (Emphasis Added).

The United States Court of Appeals, Sixth Circuit, in
1974, approved this rule in United States v. Dalpiaz,
494 F.2d 374, although this was not necessary for the

8

determination of that case. However, in United States v.
Freeland, 562 F.2d 383 (1977), the Ninth Circuit
expressly approved the rule when it held such a search
valid so long as the passenger had a right to withdraw
luggage and not board the airplane.

From a purely factual standpoint, the closest decision
to the case at bar is United States v. Homburg, 546
F.2d 1350 (C.C.A. 9th, 1977). The facts were
summarized by the Court as:

“On September 16, 1975, appellant passed through
security inspection at Western Airlines Gate One at
San Diego International Airport. His carry-on
suitcase was subjected to x-ray inspection and he
went through the magnetometer. Just prior to his
arrival at the inspection point, security officers
there were notified that an anonymous bomb
threat had been received at the airport.

As appellant passed through the inspection point,
security officers observed a rectangular bulge in
the front portion of his trousers, which he
awkwardly attempted to conceal with his suitcase.
Appellant asked for directions to the men’s room
and an officer was instructed to follow him there.
In the restroom, appellant went inside a toilet stall
and the officer heard a ‘cracking or rustling sound,
like a plastic bag or something of that nature’
(R.T. at 64), coming from inside the toilet stall.
Appellant remained inside the stall for about
fifteen minutes. When he exited, the bulge in his
trousers was gone and he was carrying his suitcase
normally. Appellant then took his place in the
boarding line, nervously watching security officers.

A security officer approached appellant and told
him he would have to be reinspected before
boarding the plane. Appellant complied and
returned to the inspection area, but upon arrival

9

indicated to the officer that he wanted to leave
the boarding area. Testimony varies as to the
precise words appellant used, but there is no
dispute that appellant indicated that he wished to
leave the boarding area and that he took a step or
two in that direction before being ‘forcibly
detained. The suitcase was then opened, contra-
band discovered and appellant was placed under
arrest.”

Although the search was upheld on other grounds, the
Court held as to the question involved herein that:

“While there is authority from this circuit to
support the government’s view of airports general-
ly, we cannot accept the government’s argument
that a passenger in'a secured boarding area may
not, as a general proposition, leave the area rather
than submit to additional searches. Such a view
runs contrary to the rationale of United States v.
Davis, 482 F.2d 893 (9th Cir. 1973). In that case,
we held that the justification for warrantless
screening searches is the implied consent of the
passenger. “(A)s a matter of constitutional law, we
stated in Davis, ‘a prospective passenger has a
choi : he may submit to a search of his person
and immediate possessions as a condition to
boarding; or he may turn around and leave.’ 482
F.2d at 913. Davis does not state specifically that
the consent to additional searches after a pre-
liminary screening may be revoked if a passenger
agrees not to board the plane. The above-quoted
portion of Davis strongly indicates, however, that a
party may revoke his consent to be searched any
time prior to boarding the plane, even when he has
passed beyond the initial screening point, if he
agrees to leave the boarding area. Other decisions
of this court have also recognized that a passenger
always maintains the option of leaving. See, e.g.,

10

United States v. Miner, 484 F.2d 1075 (9th Cir.
1973); United States v. Moore, 483 F.2d 1361
(9th Cir. 1973). We must therefore reject the
government’s view of its power to search within
the boarding area as too sweeping. Since the
undisputed evidence indicates that appellant
wished to leave the boarding area, the trial judge
erred in finding the search reasonable under the
general doctrine of implied consent.”

The search was, however, upheld because of suspicious
conduct, a bulge in the pants (gone after a trip to the
restroom) and a bomb threat that had been received.

In this case, none of these additional factors are
involved. The attendant began to search without telling
or affording Petitioner an opportunity to leave.
However, Petitioner did protest (which was verified
by the other attendant) and object but the first
attendant kept on searching.

As has been noted in the various federal cases cited
herein, two factors are obvious. The first is that
hijackings are way down and, secondly, most items
found at airport searches are not bombs or guns but
controlled substances. As hijacking has become less of a
frequent problem, we must ever keep in mind that
Courts must be ever zealous in guarding against further
invasions of personal liberties and rights merely because
we are all in agreement that the consequences of a
skyjacking can mean death to a large number of
innocent people.

Accordingly, Petitioner submits that on balance the
better view is to allow airport routine screening upon
the basis of consent so long as a passenger also retains
the right to give up his flight by revoking the consent
and leaving. There is just no evidence that this rule

»

ar’ @

—_-

encourages efforts to skyjack or that it increases
weapons at the airport. Based on this rule, the facts of
this case indicate that there was no consent and that
the search of Petitioner’s carry-on bag was illegal which
vitiates his arrest and any subsequent statements or
searches incident to arrest.

Accordingly, Petitioner submits that the better view
is that an individual may revoke consent and withdraw
and, therefore, the State of Florida has violated his
rights under the 4th and 14th Amendments to the
Constitution of the United States.

CONCLUSION

Accordingly, probable jurisdiction should be noted in
this case.

Respectfully submitted,

/s/ Selig I. Goldin

Selig I. Goldin
GOLDIN & CATES
Post Office Box 1251
Gainesville, Florida 32602
(904) 378-1673

Attorneys for Petitioner

12

CERTIFICATE OF ATTORNEY

I, SELIG I. GOLDIN, hereby certify that I am a
member of the Bar of the United. States Supreme Court
in good standing and was admitted to practice by the
Court on 17 September 1973.

/s/ Selig I. Goldin
Selig I. Goldin, Attorney At Law

CERTIFICATE OF SERVICE

| HEREBY CERTIFY that the original copy hereof
has been furnished this 14th day of June 1979 to:
THE HONORABLE MICHAEL RODAK, JR., Clerk,
United States Supreme Court, Washington, D.C., and
copies to: THE HONORABLE RAYMOND EE.
RHODES, Clerk, District Court of Appeal, First District
of Florida, Post Office Box 487, Tallahassee, Florida
32304; THE HONORABLE JIM SMITH, Attorney
General for the State of Florida, The Capitol,
Tallahassee, Florida 32304; and to THE HONORABLE
A. CURTIS POWERS, Clerk of the Circuit Court,
Eighth Judicial Circuit, Alachua County Courthouse,
Gainesville, Florida 32601.

/s/ Selig 1. Goldin
Attorney At Law

la

APPENDIX “A”

IN THE DISTRICT COURT OF APPEAL
FIRST DISTRICT, STATE OF FLORIDA

NOT FINAL UNTIL TIME EXPIRES TO FILE
REHEARING PETITION AND DISPOSITION THERE-
OF IF FILED.

CASE NO. LL-25

BRANDON H. LEAVITT,
Appellant,
v.

STATE OF FLORIDA,
Appellee.

Opinion filed April 17, 1979.

An Appeal from the Circuit Court for Alachua County.
John J. Crews, Judge.

Selig I. Goldin, of Goldin & Cates, for Appellant.

Jim Smith, Attorney General; and Lee Mandell,
Assistant Attorney General, for Appellee.

PER CURIAM.

This is an appeal from the Circuit Court in and for
Alachua County. The appellant appeals a final order
withholding adjudication of guilt a placing him on
probation with a special condition of one year in jail
and payment of $2,500 costs on a cocaine possession
count based upon a jury verdict finding him guilty of

2a

possession of cocaine under Count Two of one
information, and guilty of possession of more than five
grams of cannabis under a second information. The two
cases had been consolidated and were tried together.

Prior to trial motions to suppress were filed by
appellant in each case and were denied. A motion for
judgment of acquittal under Count Two of the second
information which charged unlawful possession of drug
paraphernalia was granted by the court.

At the trial the following facts developed: In 1977
the appellant attempted to board an airplane in the
Gainesville airport. Before being allowed to board,
appellant was required to submit himself and _ his
carry-on baggage through a predeparture screener. The
agent handling the machine could not identify an object
in his carry-on bag so she asked appellant for
permission to examine his bag in his presence. The
agent testified that defendant consented and pushed his
bag toward her and then both proceeded to search
going toward the unindentified object. However
defendant testified he did not consent to the search.
Elsa Powers, a prescreening inspector testified on
deposition that defendant did not want to be checked.
Upon the agent grasping a toilet kit, the appellant
grabbed his bag and proceeded to leave the area. The
agent was left holding the toilet kit, which had come
open in the process. She then handed the kit to Officer
Sanders of the Gainesville Police Department who
looked inside and saw five or six bags of marijuana.
Under these bags he also saw a white powder and he
began chasing appellant. Sanders yelled at appellant to
stop, that he was under arrest, but appellant continued
to flee, whereupon Sanders shot appellant in the foot.

3a

Appellant was arrested and taken to the hospital. The
total weight of the cannabis taken from appellant was
47.2 grams gross weight which included seeds, stems
and certain sticks.

An amended information was filed charging in Count
One possession of cocaine with intent to sell or deliver
and charging in Count Two simple possession of
cocaine. In a separate case, an information was filed
charging appellant with possession of more than five
grams of cannabis and with possession of drug
paraphernalia.

At trial, a state chemist testified that the substance
was cannabis and that it weighed 47.2 grams. He also
testified that based upon his tests, the white powder
was illegal cocaine. Dr. Robert Shapiro, an expert in the
field of analysis of organic compounds, testified for
appellant that there are eight isomers of cocaine and
that it would not be possible to distinguish between the
isomers based upon the tests that the state chemist
used, and that in order to prove that the cocaine
involved in a criminal case is the cocaine made illegal
by statute, additional tests must be performed. Thus a
conflict was presented to the jury on the issue of the
character of the substance in question. The jury having
resolved such conflict in favor of the State and against
the appellant, it is not the province of this court to act
as a second jury on this issue. We therefore find point
three to be without merit for the evidence
demonstrated that the illegal cocaine was a controlled
substance within the definition of that term as
proscribed by section 893.03 (2) (a)4.

Appellant contends that the trial court erred in
denying motions to suppress the evidence which

4a

revealed both the cocaine and cannabis, alleging that
the search was unreasonable. We hold that the denial of
such motions was not error. In so holding we determine
that the airport screening employees conducted a
proper search pursuant to appellant’s consent and that
the evidence affirms that the search was reasonable
under the circumstances. United States v. Cyzewski,
484 F.2d 509 (Sth Cir. 1973). Therefore the judgment
of conviction of unlawful possession of cocaine under
Count Two of the information is affirmed.

We reverse the order of probation with reference to
the cannabis count of the information for the reason
that it was not proven beyond and to the exclusion of
every reasonable doubt that the appellant was guilty of
the possession of more than five grams of cannabis, and
we remand such order to the trial court with direction
to reduce the probation sentence commensurate with a
misdemeanor charge of possession of less than five
grams of cannabis. See Purifoy v. State, 359 So.2d 446
(Fla. 1978).

Affirmed in part and reversed in part and remanded
to the trial court for the purpose hereinbefore
indicated.

MILLS, Acting Chief Judge and MASON, ERNEST E.,
Associate Judge, CONCUR. ERVIN J., CONCURS IN
PART and DISSENTS IN PART.

ERVIN, J., Concurring in part and Dissenting in part.
I concur in all portions of the majority’s opinion

with the exception of that holding it was not proven
beyond a reasonable doubt that appellant was guilty of

——

oo

Sa

possession of more than five grams of cannabis. I feel
the facts here, as in Dorsey v. State, So.2d
no. KK-240 (Fla. Ist DCA, February 9, 1979), are
sufficiently distinguishable from those which existed in
Purifoy v. State, 359 So.2d 446 (Fla. 1978). I would
affirm the order of probation in its entirety.

b

6a
APPENDIX “B”’

IN THE DISTRICT COURT OF APPEAL
FIRST DISTRICT, STATE OF FLORIDA

CASE NO. LL-25

BRANDON H. LEAVITT,
Appellant,

STATE OF FLORIDA,
Appellee.

ORDER

Motion For Rehearing And/Or Clarification and
Application For Stay Of Mandate thereto having been
considered,

IT IS ORDERED that the Motion is hereby denied.

IT IS FURTHER ORDERED that the Application is
denied.

By Order of the Court dated this 15th day of May,
A.D. 1979. Unless otherwise ordered, the Court’s
mandate will issue fifteen (15) days after this date.
Florida Rules of Appellate Procedure, 9.340; General
Order entered April 14, 1978. Acting Chief Judge E. R.
Mills, Jr., Judge Richard W. Ervin, III, and Associate
Judge Ernest E. Mason.

A TRUE COPY

ATTEST:

RAYMOND E. RHODES, CLERK

/s/ Raymond E. Rhodes
District Court of Appeal, First District
Tallahassee, Florida

OVER LITHAOCLDING ADJUDICATION OF GUILT AXO PLACING DL! CNOANT'ON
STATE OF FLORIDA F

BRANDON H. LEAVITT

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APPENDIX "B* Conse
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In the —_ CIRCUIT
Plaintiff 390 of

County, Florida

Cae No, 17=2508-CF

‘2 co ning on this day to be heard before me, and you, the defer! int, . BRANDON H. LEAVITT

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gto tes fifo fon of the Cart thet you ve not titcly ect to en, 2 ins erate? cruce of caistiet, snd

oof tice cad the wetfare of society do not require thet you should presently be edjucsed guilty 204 coffer the
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fore, it is ordcved end adjudged that the adjudication of guilt and imposition of sentence are heveby withheld,

eh. My theed on probation for a perlod of YEARS under the supervision
nt of KE YY XX ANY XY Xond Its officers, such supervision to be subject to the provisions of the laws of
CORRECTIONS

CAA Mt yt te TD comply with the followiag conditions of probation:

Bf bee Coon tee cacth any ofc ch iscoth, you will mcke a fall and truthful report to your Probation
et oF ; EE “A “or Wit pucpece.
"a Thy y tots Tf te of bho the s.covnt of Ten Doth ss ($10) por month fowsed the coct of
gee Se ee Wet y wrived ba cot oe vith Pe cla Sintates,
“oy id wot . Sy VE Pak ce Of ploy: ent oF f:.ve the comty of your re ‘2once without F..8

uastag the “at of pour Piotbation Offece, ~2s.
Hn! ve yam

FONE STI NLP SA SUR ION GSI DSA
You will live sed rowaia ot Morty yithout violating any law. A conviction In a court of lew chell not
Lo wucetascy In order for such a vivlatioa to constitute a violation of your probation.
Me an oall not use intoxicants Jo excess] nor will you visit places where intoxicants, drugs or other
Jerous substeness ure unlawfully sold, dispensed or used unlawfully.
You vill work diligently at # lawful oceupation and support any dependents to the best of your ability
va Drected Ly your Probation Officer,
You cil pro.cptly and truthfully answer all Inquiries directed to you by the Court or the Probation
O’Ccer, end -Now the Oifleer to visit In = a at your employment site or elsewhere, ond you
Vill co noly vith ell Invtivetions he may g@
Pursuant Lo Chapter 948, Florida Statutes, serve one year in an
institution of the Department of Corrections to which said
depactment may cause you to be confined. The Court recommeuds that
you be incarcerated at the Indian River Correctional Center which has
an innovative youthful offender program.
’ay $2500 fine or costs.

Kc bexpot y, ht si a4 Ca!eBs-r a

Vea are tr eeby pl ced oa notice thit the Cou
Moa or my eete. dite

ee may at any Cina tosvind or niattif
PEt iP yon sialate

y any cf the condkions of your
i tied Of probation ag authoriccd by law, or inay discharsa you from further supervision;
y of Iho conditions of your piobst!

Shan, You nay ba enesled cud the Court Hisy revoke your
PEO IR, BE ee yok Soy atd banpose any tenivence vision i right have hapoced befcce plecing you on probstion,
PUSH om you hate nomied tot ba" Som Givicge ad ove Sica destruct d .3 to the
ow BOF ye Valen you eM be relecsed from custody if you a.r ine ody ond if you ore at Nverty on bond, the
a; me Wostid Cieharged from fist ity,

Bets fort or erdored that the Clerk of thi
Coiet, ob Gu. ith r

routs of bow,

$s Court file this over j

n his office, record the rome in the Minutes of the
vite corttiod copies of some to the Probesti

on Officer for his use in comptiance with the require

VOSE AND ORDERED IN OPEN COURT, this the oo. y

— AUGUST, 1978,

> & \ / Judge

5 KS - a “3: : SSMS SL 97% Broz. eh
touche. Oe eIpt Of a Cid copy of this order and Kat the conditions have been explained to me.
es _—_ a —
Probationer
Instruct di by ccuantnstunthensectpeninnt:
Org vel Court sag prea
Copies Nobationer 5 a
File

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385006_0330%3A1. Public record. Not legal advice.
