Billiot v. State

In Billiot v. State, 711 So. 2d 1277, 1278-79 (Fla. 1st DCA 1998), the First District disagreed with the Fifth District's decision in Crawford. The First District reasoned that since the State must prove an additional element to convict on an aggravated battery charge, as opposed to a simple battery charge, subsection 775.21(4) authorizes separate punishments for first-degree burglary with a battery and aggravated battery. See Billiot, 711 So. 2d at 1279.