In Negron v. State, 306 So. 2d 104 (Fla. 1974), the defendant was convicted of grand larceny for the theft of items valued at more than $ 100. On appeal, the court held that the State had not presented sufficient evidence of the value of the items and thus the degree of the crime, whether grand or petit larceny, had not been established beyond a reasonable doubt. This issue was presented as a claim of fundamental error on appeal in Negron, and the court reduced the conviction to petit larceny.