What did the court decide?

The court affirmed the conviction and sentence but ordered the trial court to remove a $100 investigative-costs fee because the State never requested those costs.

Who is affected by this decision?

Brent Paul Venrooy is affected directly; the trial court must correct the judgment. The decision also reiterates that defendants generally cannot be required to pay investigative costs unless the State requests them.

What happens next in the case?

The case is remanded to the trial court to enter a corrected judgment striking the $100 investigative-costs fee.

Can this decision be appealed further?

The opinion notes it is not final until disposition of any timely and authorized motion under Florida Rule of Appellate Procedure 9.330 or 9.331, so limited further review or rehearing may be possible within those rules.

Brent Paul Venrooy v. State of Florida

Docket 5D2025-0345

Court of record · Indexed in NoticeRegistry archive · AI-enriched for research

Criminal Appeal

Filed: Apr 17, 2026 · 2 weeks ago
Jurisdiction: Florida
Court: District Court of Appeal of Florida
Type: Opinion
Case type: Criminal Appeal
Docket: 5D2025-0345

Appeal from a criminal judgment and sentence in the Circuit Court for St. Johns County following an Anders brief

Summary

The Fifth District Court of Appeal affirmed Brent Paul Venrooy’s criminal judgment and sentence after an Anders brief, finding no reversible error in the conviction or sentencing. The court did, however, remand to the trial court to enter a corrected judgment removing a $100 investigative costs fee because the State never requested investigative costs. The court relied on Richards v. State to hold that investigative costs may be imposed only when the State has expressly requested them. The panel issued its decision per curiam on April 17, 2026.

Issues Decided

Whether any reversible error existed in appellant's conviction or sentence under an Anders review
Whether the trial court may impose investigative costs when the State did not request them

Court's Reasoning

Under Anders, the appellate court reviewed the record and found no meritorious issues to overturn the conviction or sentence, so the judgment and sentence were affirmed. However, the court applied Richards v. State, which requires the State to request investigative costs before a defendant may be ordered to pay them, and concluded the $100 investigative-costs fee must be stricken because the State never requested such costs.

Authorities Cited

Anders v. California386 U.S. 738 (1967)
Richards v. State288 So. 3d 574 (Fla. 2020)

Parties

Appellant: Brent Paul Venrooy
Appellee: State of Florida
Judge: R. Lee Smith
Attorney: Thomas J. Butler
Attorney: Daniel P. Caldwell

Key Dates

Opinion date: 2026-04-17

What You Should Do Next

1
Enter corrected judgment
The trial court clerk should prepare and enter a corrected judgment that omits the $100 investigative-costs fee as directed by the appellate court.
2
Counsel review for post-opinion motions
Defense counsel should consider whether to file any timely motions for rehearing or clarification under Fla. R. App. P. 9.330 or 9.331 if they wish further review.
3
Confirm credit and accounting
After the corrected judgment is entered, counsel or the defendant should verify the court's financial ledger and any restitution or fee notices to ensure the $100 charge is removed from obligations.

Frequently Asked Questions

What did the court decide?: The court affirmed the conviction and sentence but ordered the trial court to remove a $100 investigative-costs fee because the State never requested those costs.
Who is affected by this decision?: Brent Paul Venrooy is affected directly; the trial court must correct the judgment. The decision also reiterates that defendants generally cannot be required to pay investigative costs unless the State requests them.
What happens next in the case?: The case is remanded to the trial court to enter a corrected judgment striking the $100 investigative-costs fee.
Can this decision be appealed further?: The opinion notes it is not final until disposition of any timely and authorized motion under Florida Rule of Appellate Procedure 9.330 or 9.331, so limited further review or rehearing may be possible within those rules.

The above suggestions and answers are AI-generated for informational purposes only. They may contain errors. NoticeRegistry assumes no responsibility for their accuracy. Consult a qualified attorney before relying on them.

Full Filing Text

FIFTH DISTRICT COURT OF APPEAL
                STATE OF FLORIDA
                 _____________________________

                      Case No. 5D2025-0345
                 LT Case No. 2023-001316-CFMA
                  _____________________________

BRENT PAUL VENROOY,

    Appellant,

    v.

STATE OF FLORIDA,

    Appellee.
                 _____________________________


On appeal from the Circuit Court for St. Johns County.
R. Lee Smith, Judge.

Thomas J. Butler, of Thomas Butler, P.A., Miami Beach, for
Appellant.

James Uthmeier, Attorney General, Tallahassee, and Daniel P.
Caldwell, Assistant Attorney General, Daytona Beach, for
Appellee.

                         April 17, 2026


PER CURIAM.

    In this Anders1 appeal, we affirm Appellant’s judgment and
sentence. However, we remand for the entry of a corrected
judgment striking the $100 fee for investigative costs because the

    1 Anders v. California, 386 U.S. 738 (1967).
investigative costs were never requested. See Richards v. State,
288 So. 3d 574, 577 (Fla. 2020) (“[T]he State must request
investigative costs to make a defendant liable for those
costs . . . .”).

    AFFIRMED and REMANDED with instructions.


JAY, C.J., and LAMBERT and EISNAUGLE, JJ., concur.

                _____________________________

    Not final until disposition of any timely and
    authorized motion under Fla. R. App. P. 9.330 or
    9.331.
               _____________________________




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