Deegan v. State

The trial court, without giving any written reasons for doing so, imposed a sentence for revocation of probation that constituted a two-cell deviation from the guideline sentence for appellant’s underlying offense of battery on a law enforcement officer. Although a trial court may make a one-cell deviation from the guidelines after revocation of probation without giving a reason for departure, written reasons for departure must accompany any greater deviation. The Florida Bar Re: Rules of Criminal Procedure, 482 So.2d 311 (Fla.1985); Rule 3.701(d)(11), (14), Fla.R.Crim.P.; Carter v. State,…