Hicks v. State

Petitioner alleges that his appellate counsel was ineffective on appeal from a revocation of probation. Petitioner contends that his appellate counsel was ineffective in failing to argue that the trial court did not orally pronounce the standard and special conditions of probation and did not timely file a written order of probation. This issue was not preserved below, but counsel should have filed a rule 3.800(b) motion. See, e.g., Flowers v. State, 965 So.2d 1233 (Fla. 1st DCA 2007).

This court in Jones v. State, 876 So.2d 642 (Fla. 1st DCA 2004), stated that general conditions may be…