MAURICE SHUNTELL MITCHELL
v.
STATE OF FLORIDA

Fla. 1st DCA | 2026-05-13
No. 2025-1024
Miller-Jones, J., Lewis, J., Roberts, J., Kelsey, J.
2026 FL 5507 Florida District Court of Appeal, First District (2026)

AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.


Holding

A trial court errs in awarding restitution for a victim's Medicare Part B premium and remaining car loan balance when the premium is not for medical treatment related to the defendant's conduct and the loan balance is a product of the victim's financial decision rather than the defendant's conduct.


Headnotes

[1] A victim's Medicare Part B premium for coverage is not a proper subject of restitution under Florida law when it does not represent medical treatment related to the defen…

[2] A remaining balance on a victim's car loan is not a proper subject of restitution when insurance has paid the fair market value of the vehicle and the unpaid balance resu…

Previewing 2 of 2 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.

Join FLexlaw to unlock all legal intelligence

Key Quotes

“a product of [the victim's] financial decision”

The court explained why the remaining car loan balance was not properly restitutable, citing Tolbert v. State.

Facts & Procedural History

Maurice Mitchell was convicted and the trial court ordered him to pay restitution for four items, including the victim's Medicare bill and car loan ba…

The full statement of facts, procedural history, and disposition for this case are member content.

Join FLexlaw to unlock all legal intelligence

© FLexlaw, Inc. — AI-generated enrichments are proprietary. All rights reserved.

Opinion of the Court

FIRST DISTRICT COURT OF APPEAL

STATE OF FLORIDA

No. 1D2025-1024

MAURICE SHUNTELL MITCHELL, Appellant,

V.

STATE OF FLORIDA, Appellee.

On appeal from the County Court for Alachua County. Susan Miller-Jones, Judge.

May 13, 2026

PER CURIAM.

Maurice Mitchell appeals the trial court's order setting restitution. He argues that the trial court erred in awarding restitution for four items, only two of which merit discussion. We agree that the trial court erred in awarding restitution for the victim's Medicare bill because it encompasses her Medicare Part B premium for a six-month coverage period, not medical treatment related to her injuries from the accident. See §§ 775.089(1)(a) & (2)(a), Fla. Stat. (2024). We also agree that the trial court erred in awarding restitution for the victim's car loan balance. Because insurance paid out the fair market value of the car, the remaining balance on the loan was “a product of [the victim's] financial decision," not Appellant's conduct. Tolbert v. State, 268 So. 3d 947, 948-49 (Fla. 1st DCA 2019).

We therefore AFFIRM in part, REVERSE in part, and REMAND for entry of a corrected restitution order.

LEWIS, ROBERTS, and KELSEY, JJ., concur.


Cases With Similar Vibessemantic neighbors from the corpus


Citator

Authorities Cited

Full citator, related cases, and AI research tools

Open in FLexlaw