Cases | Graham v. State, 720 So. 2d 294 (Fla. Dist. Ct. App. 1998) | 2018

The defendant was convicted of armed robbery with a firearm and of grand theft and was ordered to pay to the victim $640 in restitution, including actual damages and lost wages. On appeal, the defendant argued that the lost wages portion of the award “was improper because the state failed to submit competent evidence regarding the victim’s claim for lost wages.” The court of appeals held that, because no evidence was offered by the State documenting how much the victim lost in wages, that portion of the order was improper. The court affirmed the defendant’s convictions and sentences, but vacated the portion of the order of restitution for lost wages.