Willner v. Department of Prof. Reg

In Willner v. Department of Prof. Reg., 563 So. 2d 805, 806 (Fla. 1st DCA 1990), a statute authorized placing a physician on probation "subject to such conditions as the board may specify." A board imposed a special condition that the physician pay $ 60,000 for use in consumer protection. The court found that this payment was a penalty, which could only be upheld if the legislature had evinced the specific intent to authorize exacting monetary penalties as conditions of probation. See 563 So. 2d at 806.