State v. Valerie F. Platt

The State appeals the downward departure sentence imposed against Valerie Platt for the crime of making a false report of a bomb in violation of section 790.163, Florida Statutes (2015), a second-degree felony. Specifically, the State argues the trial court erred when it withheld adjudication of guilt on the offense without a written request to do so from the State and without competent, substantial evidence to support its decision. We agree and reverse.

Platt was charged with making a false report of a bomb, attempted robbery, and making a false report to law enforcement after her scheme to…