Special Report · In Depth

Florida's Ankle-Monitor Box: A Brief Separation, an Arrest, and Weeks in Jail

Most people on Florida's state GPS monitoring wear a bracelet on the ankle and must also keep a separate tracking unit, "the box", within range at all times. Florida's appeals courts have said more than once that walking away from that unit for a few minutes, without intent, is not a willful and substantial violation of probation. Florida's arrest and no-bail rules, though, can keep a person in jail for weeks or months before any judge reaches that question. This report sets out what the equipment requires, what the law says at each stage, what the public record shows about how long people wait, and what we could not verify.

Published October 22, 2026 · Updated October 22, 2026 (Georgia, New Mexico and the national picture added) · Registry Wire Desk · Sources read October 21–22, 2026 · Not legal advice

What this report found

Each finding is sourced in the section it points to
  • Record Florida's state contract is for two-piece equipment. The Department of Corrections' GPS contract (C2929) runs to June 30, 2028 and is now held by Allied Universal. Its renewal pricing is for a "TWO PIECE MODEL" on active GPS. Its equipment schedule also lists an Attenti one-piece tracking device. Nationally, a 2016 study prepared for the National Institute of Justice found single-piece systems are the more common choice, and Georgia's 2016 statewide award was for single-piece GPS. The equipment · Other systems
  • Record The appeals court whose decisions bind Leon County judges has held that a brief walk away from the unit is not enough. In King v. State (Fla. 1st DCA 2019), a man left the unit on its charger for about five minutes. The court held that this "is not competent, substantial evidence of a substantial and willful violation." Channell (1st DCA 2016) and Douglas (2d DCA 2022) reversed on similar reasoning. The case law
  • Record The law does not treat every separation as innocent. In Santos v. State (1st DCA 2024), a revocation was affirmed after a 49-minute "bracelet gone" alarm, earlier alarms, and an admission that the man had read the carrying rules and did not follow them. The affirmance was unexplained, and the reasoning is one judge's concurrence, so it sets no precedent. The case law
  • Record Arrest comes first, and the hearing comes later. A probation officer "may" arrest without a warrant on "reasonable grounds" to believe a material violation occurred. Willfulness is decided only at the hearing. Three stages
  • Record For many people on sex-offense probation, Florida law forbids bail while the violation is pending. A "violent felony offender of special concern" "shall remain in custody pending the resolution" of any violation other than nonpayment. The court may not dismiss the warrant without a recorded hearing. For other registrants a judge must first find the person "not a danger to the public." In Leon County, a probation-violation warrant that is silent on bond means "no bond." Why the wait
  • Record Leon County's own figures show the length of the wait. The county's Public Safety Coordinating Council reported that people jailed only on a probation violation averaged 87 days in 2022 and 56 to 62 days in late 2023 and early 2024. The figures do not separate equipment violations from others. Why the wait
  • Not verified We found no public record of the specific sequence reported to us: probation reinstated, then the person kept in jail for weeks afterward. We found no news report of receiver-separation arrests in Leon County, no lawsuit challenging the two-piece requirement, and no published department policy on how to respond to a separation alert. Unresolved

What was reported to us, and what we could verify

A firsthand account is where this began. It is not the evidence.

This report began with a firsthand account from a reader in the Tallahassee area. The reader said four people they know, several of them older, were in jail after leaving the separate tracking unit in a car, a home or a room, in at least one case for about fifteen minutes. The reader also said that in some cases probation was reinstated but the person stayed in jail for weeks or months while paperwork, transfers or court dates were sorted out.

Reported We have not identified, contacted or examined the records of those four people, and we do not name them. We have not independently confirmed the length of any separation, the date of any arrest, the date of any reinstatement or the date of any release. Nothing below should be read as confirming those accounts.

What the public record does show is the machinery those accounts describe. The equipment requires a separate unit. Separations generate alerts. Officers have arrest authority on reasonable grounds. Appellate courts have reversed violation findings for short, unintentional separations. And Florida's detention rules can hold a person on supervision for a sex offense until a hearing is held. Each piece is documented below with its source. Whether the four accounts fit that pattern can only be confirmed from their court files, which are public in Florida and which their families or lawyers can obtain (see Records & comment).

On scope. The Registry Wire does not report on individual arrests. This report is about a practice: how an equipment rule, an arrest power and a detention statute interact. The court cases discussed are published appellate decisions.

How the two-piece system works

From the state contract record, legislative audits and the vendor's own materials

Who wears it

For people on probation or community control for certain sex offenses against a victim 15 or younger, and for designated sexual predators, monitoring is mandatory. Florida law says the court "must order … mandatory electronic monitoring as a condition of the probation or community control supervision" (§ 948.30(3), Fla. Stat.). For other sex-offense probation, it is a discretionary condition ordered "at the recommendation of the Department of Corrections" (§ 948.30(2)(e)). Florida's Auditor General counted 5,401 people on electronic monitoring as a condition of state community supervision in January 2021 (Report 2024-108). The Legislature's research office reported that as of November 2024, "67% of sex offenders on FDC community supervision were on active electronic monitoring" (OPPAGA Report 24-11).

The contract and the device

The Department of Corrections buys GPS monitoring under contract C2929, "GPS Monitoring Services." It was awarded by invitation to negotiate and began July 1, 2018. The state's contract-tracking system now lists the vendor as Allied Universal Electronic Monitoring, a total value of $149.4 million and an end date of June 30, 2028 (Florida Accountability Contract Tracking System, C2929). When it won the contract in 2018, Attenti, then the vendor, announced it would provide "their newest two-piece monitoring device, RTC" for "the department's 7,300 probation, parole and community release populations" (Attenti release, July 2, 2018).

The contract record shows which equipment is in use:

  • Its pricing for renewal years 7 to 10 is for "TWO PIECE MODEL; Supervision Level: ACTIVE GPS."
  • Its replacement-fee schedule lists the two-piece "XT" and "RTC" tracking devices at $900 each, a two-piece bracelet at $100 and a home curfew base unit.
  • The same schedule also lists an "Attenti One-Piece Tracking Device 4 (TD4)" at $1,050 and a one-piece beacon. So a one-piece device is part of the contract.

The record does not show how many, if any, people under state supervision wear the one-piece device. The current vendor advertises both a one-piece (AT1) and a two-piece (RTC) GPS product (Allied Universal).

The vendor's brochure describes the RTC as a unit that "transmits location data and alert status via LTE and Wi-Fi networks." It says the ankle transmitter "vibrates to notify the participant of a potential range violation," an "optional feature" that "can be customized to fit your program needs" (Attenti RTC brochure). We could not find a published figure for how far apart the bracelet and unit can be before an alert fires, or whether Florida has the vibration warning switched on.

What it is like to carry

Florida's equipment has been two-piece for a long time. In 2015 the Legislature's research office described the system then in use as providing "two pieces of equipment to each offender—a smart XT tracking/communication device and an affixed ankle bracelet" (OPPAGA Report 15-16).

A 2010 study of Florida's program, funded by the National Institute of Justice and carried out by Florida State University, put the daily rule plainly. People "are required to wear EM ankle bracelets and carry their MTDs [monitoring tracking devices] at all times or have the boxes in their docking stations when they are home." It found that alerts occur when people "cut the straps of the ankle bracelets or when they are not in close proximity to their MTDs" (Bales et al., A Quantitative and Qualitative Assessment of Electronic Monitoring).

In a 2024 First District case, the probation officer described the current RTC unit as a device similar to a cell phone, carried in a case, with a written instruction that "The tracking device must be carried only in the approved carrying case." The officer also testified that "All probationers wearing this equipment are allowed a three-minute grace period when an alarm signal is received, in which case no violation is filed." During that time "the Department's contractor attempts to contact the probationer for up to eight minutes, at which time the probation officer is notified when no response is received" (Santos v. State, B.L. Thomas, J., concurring). That is testimony in one Bay County case, reported in one judge's concurrence. It is the most specific public description of the grace period we found, but it is not a published policy.

State and county programs are different. Felony probation, including sex-offender probation, is supervised by the state Department of Corrections. Leon County separately runs GPS monitoring for its own pretrial-release and county-probation clients through its Office of Intervention and Detention Alternatives. The County Commission approved a contract with Sentinel Offender Services in July 2024 (Board agenda, July 9, 2024; FY 2026 budget, Intervention and Detention Alternatives). The county program's equipment and rules are not the state's. Most people on sex-offense probation are under the state program.

What the written rules say about alerts

The statute requires procedures. The procedures themselves are not public.

The statute governing electronic monitoring sets one clear duty. "The Department of Corrections shall develop procedures to determine, investigate, and report the offender's noncompliance with the terms and conditions of sentence 24 hours per day. All reports of noncompliance shall be immediately investigated by a probation officer" (§ 948.11(3), Fla. Stat.). The department may contract with local police "to assist in the location and apprehension of offenders who are in noncompliance," especially after hours (§ 948.11(4)). The statute sets no response time and does not mention a monitoring center. It does not say how a short separation should be handled.

The only official description of alert handling we found is the Legislature's 2015 review. It reported that "In most instances, an offender is given the opportunity to respond to an alarm by modifying his or her behavior or correcting a technical problem before it results in a violation of probation." The vendor's monitoring center gave the first response to routine alarms. "Some alarms, because of their seriousness, bypass the monitoring center and go directly to the assigned probation officer," it said: a broken strap, tampering, entering an exclusion zone or leaving an inclusion zone. The contract goal was for the center to handle 70% of alarms, and in September 2015 it resolved 72% (OPPAGA 15-16). The report does not say which category a bracelet-out-of-range alarm falls into.

When the Auditor General reviewed the department's monitoring controls in 2019, it found they "need improvement." It withheld the details, stating: "We are not disclosing specific details of the issues in this report to avoid the possibility of revealing Department surveillance techniques or procedures" (Report 2020-006, Finding 8). A 2024 follow-up said the department had taken corrective action (Report 2024-108).

Not found We found no published Department of Corrections procedure, rule in the Florida Administrative Code or training document that:

  • defines a receiver-separation alert;
  • distinguishes an accidental separation from concealment or absconding;
  • requires an officer to try to reach the person before seeking a warrant; or
  • tells officers when not to arrest.

Such procedures may exist; § 948.11(3) requires some. The auditor's practice suggests they are treated as confidential. They are the first item in the records requests set out below.

Arrest, violation and release are three different decisions

Different people decide each one, on different standards
  1. 1. Arrest or warrantA probation officer "may arrest" without a warrant, or have police do it, when there are "reasonable grounds to believe" a material violation occurred. A judge may instead issue a warrant on an officer's sworn affidavit. The decision is made on the alert and the officer's investigation, before anyone has decided whether the separation was willful. (§ 948.06(1)(a)–(b))
  2. 2. Finding a violationAt a hearing, the State must prove a willful and substantial violation by the greater weight of the evidence, and it may not rely on hearsay alone. The judge may then revoke, modify or reinstate probation. (case law below)
  3. 3. ReleaseWhether the person waits in jail before the hearing depends on bond and the detention statute. Once a judge orders release or reinstatement, the jail and the supervising agency carry the order out. Delays at that point are governed by different law again. (detention, after reinstatement)

The statute gives officers alternatives to arrest, but each is limited:

  • Notice to appear. A judge may issue a notice to appear instead of a warrant, but only if the person "has never been convicted of committing, and is not currently alleged to have committed, a qualifying offense" (§ 948.06(1)(b)). The list of qualifying offenses includes the main sexual-battery, lewd-conduct and child-pornography statutes, so the notice is not available to many people on sex-offense probation.
  • Notification letter. The chief judge of a circuit may direct the department "to use a notification letter of a technical violation in appropriate cases in lieu of a violation report, affidavit, and warrant" (§ 948.06(1)(h)).
  • Alternative sanctioning program. For any "technical violation", meaning one "that is not a new felony offense, misdemeanor offense, or criminal traffic offense", the officer "shall determine" whether the person is eligible for the program (§ 948.06(1)(c), (9)).

Whether the Second Judicial Circuit, which covers Leon County, has issued a notification-letter direction, or an order adding equipment violations to its sanctioning program, is something we could not confirm (Unresolved).

Arrest is not a finding. An arrest on reasonable grounds is lawful even if a judge later finds the separation was accidental. That is why a person can be lawfully arrested, held for weeks and then reinstated with no violation found. Each step can be lawful on its own terms while the total time in custody exceeds anything the alleged violation could justify.

What Florida's appeals courts have said

Opinions read in full; holdings separated from concurrences and dicta

The standard

In Florida, a probation violation must be willful and substantial. The Florida Supreme Court has said each violation is judged case by case on whether it is "willful and substantial and … supported by the greater weight of the evidence" (State v. Carter, 835 So. 2d 259, 261 (Fla. 2002), as quoted in Santos). The Second District put the corollary in Douglas: "A violation of probation will not be found where the violation is due to negligence or ineptitude." Willfulness is also defeated by "a reasonable, good faith attempt to comply, and factors beyond his control." Applied to monitoring equipment, the courts have drawn the line this way: "intentional disregard of the GPS monitoring rules, tampering with the equipment, or actual violations of curfew" will generally amount to willful and substantial violations, but "equipment problems or the subject's unintentional failure to operate equipment properly" do not (Channell, quoting Edwards v. State, 60 So. 3d 529, 532 (Fla. 2d DCA 2011)).

Which decisions bind Leon County judges

Leon County is in the Second Judicial Circuit, and appeals from it go to the First District Court of Appeal. Under Pardo v. State, 596 So. 2d 665 (Fla. 1992), a district court's published decision binds every Florida trial court unless another district has ruled differently. Where the districts conflict, a trial court follows its own district. First District decisions such as King and Channell therefore control in Leon County. An unexplained "per curiam affirmed" decision such as Santos is not precedent, and a concurrence binds no one.

Opinions are linked in the text below. "Binding" means a published majority holding; "persuasive" means everything else.
CaseEquipment factsResultWeight
King v. State, 268 So. 3d 936 (Fla. 1st DCA 2019)Left the unit on its charger at a shelter's welcome center for about 5 minutes; told the monitoring company what happened when it calledReversed: brief separation is not a willful, substantial violationBinding holding, First District
Channell v. State, 200 So. 3d 247 (Fla. 1st DCA 2016)Ankle bracelet plus hand-held monitor; ten "bracelet gone" countsReversed: hearsay alone; alerts "typically cleared within a reasonable time"Binding holding, First District
Douglas v. State, No. 2D20-3196 (Fla. 2d DCA Feb. 11, 2022)Lost his RTC unit, which caused a "bracelet gone" alert; sentenced to 364 days in jailReversed, with probation to be reinstated: no evidence the loss was willfulBinding holding, Second District
Correa v. State, 43 So. 3d 738 (Fla. 2d DCA 2010)Twelve "bracelet-gone" alerts while on his own porch; unit not seated in its chargerReversedBinding holding, Second District (read through a secondary copy)
de la Rosa v. State, No. 2D22-1284 (Fla. 2d DCA 2023)Officer's order to plug in the RTC by 10:00 p.m.Reversed: a set charging time was a new condition the court never imposedBinding holding, Second District
Santos v. State, No. 1D2022-3499 (Fla. 1st DCA Oct. 2, 2024)Put the RTC in his pocket, lost it at a store, 49-minute alarm, earlier alarms, admitted not following written ruleAffirmed without opinionNot precedent; reasoning is one judge's concurrence
Romero v. State, No. 5D19-2570 (Fla. 5th DCA 2020)GPS showed travel outside the permitted areaAffirmed: Archie (5th DCA 2019) sets no per se rule; willfulness "remains a fact-specific inquiry"Binding holding, Fifth District

King v. State (First District, 2019)

Troy King lived in a homeless shelter in Alachua County. The State's evidence was that "on one occasion, appellant moved away from the device for approximately five minutes before returning to it." He said he had left it "on the charger in the welcome center of the homeless shelter where he resided and walked into the cafeteria," and he explained this when the monitoring company called him. The trial court found a willful and substantial violation, revoked probation and reinstated it with modified terms.

The First District reversed. Its holding: "The State failed to present any evidence that appellant intentionally violated the electronic monitoring rules. Evidence that a probationer walked away from a monitoring device for a brief period of time is not competent, substantial evidence of a substantial and willful violation." The same opinion reversed two other findings. One was for missing sex-offender treatment he could not afford. The other was for falling more than $800 behind on the $4.50-a-day monitoring fee, because the State offered no proof he could pay (opinion).

What it decided: on that record, a five-minute separation with no evidence of intent could not support a violation. What it did not decide: how long is "brief," or what happens when there is a pattern of separations. It did not say an officer may not arrest on such an alert.

Channell v. State (First District, 2016)

Channell wore a GPS ankle bracelet and carried a hand-held monitor. The State charged him with ten "bracelet gone" alerts. The First District reversed on two independent grounds. First, "probation or community control may not be revoked solely on the basis of hearsay evidence." The officer had testified from her own notes, with no witness from the monitoring company to lay the business-records foundation. Second, there was no willful and substantial violation, because "the alerts were typically cleared within a reasonable time" and there was no evidence of "intentional disregard of the GPS monitoring rules" or tampering (opinion).

Douglas v. State (Second District, 2022)

Douglas was on probation in Lee County after community control for failing to register. The trial court found he violated probation "by losing his RTC GPS Unit on 8/15/20 at about 12:47 am, which caused a bracelet gone alert … [w]ith a replacement cost of $1050.00." It sentenced him to 364 days in jail, with 165 days' credit. The court noted that "none of the testimony explained how the GPS unit arrived at its eventual resting point."

A unanimous panel reversed: "the record contains no evidence that Douglas willfully acted in a manner to cause the loss of the GPS unit," and "no evidence established a deliberate act of misconduct by Douglas causing his noncompliance." It remanded "for reinstatement of Douglas's probation" (opinion). The opinion distinguishes cases that affirmed for repeated failures. In one, the probationer had twice failed to carry the device, with ten low-battery alarms and 21 "bracelet gone" notices (Soliz, 18 So. 3d 1094).

What it did not decide: Douglas does not say that losing a unit can never be willful. It is a holding that this record lacked proof of willfulness. The alert was in August 2020 and the reversal came in February 2022. The opinion does not say how much of the 364-day sentence was served before that.

Santos v. State (First District, 2024)

The entire decision of the court is: "PER CURIAM. AFFIRMED." Judge B.L. Thomas wrote a concurrence, and it is the only reasoning in the case. Santos was on sex-offender probation in Bay County, and this was his second violation.

  • The facts. The affidavit alleged a "bracelet gone alarm for approximately 49 minutes." At a Lowe's he put the RTC in his pocket instead of its required case, lost it, and then ate lunch. Earlier alarms "had occurred several other times," and he conceded "he had read the requirements but just did not comply."
  • The concurrence's reasoning. Judge Thomas concluded the trial court did not abuse its discretion in finding the violation willful: "he just made a unilateral decision that it was inconvenient." He added: "Probationers are not entitled to endanger public safety by violating the requirements of electronic monitoring" (decision and concurrence).

How it fits with King: the two cases do not conflict. What separated them was not the number of minutes alone. In Santos there was evidence of a known rule, an admitted choice not to follow it and a history of alarms. In King there was none. Santos does not hold that every separation justifies arrest or revocation.

Other decisions

  • de la Rosa v. State (2d DCA 2023). Requiring a probationer to keep the device charged is permissible: "a probationer in possession of electronic monitoring equipment may fairly be required to maintain that equipment to the extent he or she is reasonably capable of so doing." But an officer's specific plug-in deadline "essentially imposes a new condition of probation" that only the court can impose (opinion). The point matters here because the specific rules about where the unit must be kept, such as the carrying case, come from the department's instructions, not the court's order.
  • Correa v. State (2d DCA 2010). Twelve "bracelet-gone" alerts while Correa was on his own porch did not establish a willful violation. We read this one through a secondary copy only.
  • Romero v. State (5th DCA 2020). The court held that its earlier decision in Archie sets no blanket rule, and that willfulness "remains a fact-specific inquiry" (opinion). Archie had reversed where a GPS device's alert function was switched off.

Why the wait in jail can be long

The statute, the local bond order, and Leon County's own jail figures

Under the general rule, at first appearance the court "may commit the probationer or offender or may release the person with or without bail to await further hearing." The court must give the person a hearing "as soon as may be practicable" (§ 948.06(2), Fla. Stat.). For people on supervision for a sex offense, three further rules narrow that discretion, sometimes to nothing.

1. No bail at all for a "violent felony offender of special concern"

Florida's 2007 Anti-Murder Act created this category. It covers anyone on felony probation or community control for a "qualifying offense" committed after the Act took effect. It also covers some people with an earlier qualifying conviction or a sexual-predator designation. The qualifying offenses include the listed subsections of the sexual-battery statute (§ 794.011), the listed lewd or lascivious offenses under § 800.04, sexual performance by a child under § 827.071, and listed computer-pornography and child-sexual-abuse-material offenses. The statute provides:

"In the case of an alleged violation of probation or community control other than a failure to pay costs, fines, or restitution, the following individuals shall remain in custody pending the resolution of the probation or community control violation: 1. A violent felony offender of special concern … The court shall not dismiss the probation or community control violation warrant pending against an offender enumerated in this paragraph without holding a recorded violation-of-probation hearing at which both the state and the offender are represented." — § 948.06(8)(d)

The rule has no exception for equipment or technical violations. A person in this category who is arrested on a separation alert stays in jail until the hearing, however brief the separation. If the judge finds a violation, the court must make written findings on dangerousness. If the person is found to pose a danger, "the court shall revoke probation and shall sentence the offender up to the statutory maximum" (§ 948.06(8)(e)). People in this category are also excluded from the alternative sanctioning program (§ 948.06(9)).

2. A danger finding before release for other registrants

For people on probation for listed sex offenses, or who are registered sex offenders or sexual predators, "the court must make a finding that the probationer or offender is not a danger to the public prior to release with or without bail" (§ 948.06(4)). The court may also weigh "whether the probationer or offender is more likely than not to receive a prison sanction for the violation." Florida's procedural rule says that hearing comes "no sooner than 24 hours after arrest" (Fla. R. Crim. P. 3.790(b)(2), read in the court system's compilation of the rules).

3. "No bond" on a silent warrant in Leon County

The Second Judicial Circuit's 2026 uniform bond schedule provides that for "Violation of Probation or Failure to Appear Warrants," bond is "In the amount provided for in the warrant itself." "If the warrant is silent as to a bond amount, then there will be no bond and first appearance is required." It also bars release before first appearance for anyone who, "at the time of arrest for any felony," is on probation or community control, or who is designated a sexual offender (Administrative Order 2025-02).

The alternative sanctioning program does not list equipment failures

Florida requires every circuit to run an alternative sanctioning program for technical violations (§ 948.06(9)(a)). The statute's list of "low-risk" violations includes:

  • a positive drug test;
  • failing to report;
  • a missed class or treatment session;
  • a curfew violation;
  • leaving the county without permission.

It does not list an electronic-monitoring failure. Such violations qualify only as "any other violation as determined by administrative order of the chief judge of the circuit" (§ 948.06(9)(b)11). Electronic monitoring for up to 90 days is itself one of the program's sanctions. Participation is voluntary, and any sanction must be approved by the court.

What Leon County's figures show

Leon County's Public Safety Coordinating Council tracks the jail population by case type. In the minutes and weekly reports we read, people held only on an open probation violation averaged the following:

"Average days in jail since last arrest." The reports do not distinguish technical violations from new-law violations, or equipment violations from others.
Report dateHeld on open VOP onlyAverage daysSource
April–May 2022108 people87PSCC minutes, May 17, 2022
December 4, 202391 people56PSCC agenda materials, Jan. 30, 2024
January 24, 202496 people62

For comparison, the same reports showed people held on a probation violation plus other pending charges averaging 183 to 206 days. A consultant's study of the Leon County jail, as reported by WCTV, found that "the average length of stay for those facing probation violations was just over a month in 2019" and "nearly two months" by 2023. The study also found that the time from first appearance to sentencing on a probation violation ran about 20 days longer than the 37 days the consultants called typical (WCTV, Oct. 8, 2024).

These are averages for all probation violations. They do not show how long anyone held on a receiver-separation alert waited. They do show that in Leon County a probation-violation hold, even with no new charge, has typically meant weeks to months in jail.

The constitutional floor

The U.S. Supreme Court has held that a probationer is "entitled to a preliminary and a final revocation hearing, under the conditions specified in Morrissey v. Brewer" (Gagnon v. Scarpelli, 411 U.S. 778 (1973)). Morrissey calls for "some minimal inquiry" "as promptly as convenient after arrest" and a final hearing "within a reasonable time." It added that "A lapse of two months … would not appear to be unreasonable" (Morrissey v. Brewer, 408 U.S. 471 (1972)).

How Florida courts have applied the preliminary-hearing requirement to probationers brought before the sentencing court is a question we did not resolve (Unresolved). Once the violation affidavit is filed, the probation term itself is tolled "until the court enters a ruling on the violation" (§ 948.06(1)(g)).

After reinstatement: when release itself is delayed

The legal standard is clear. The local evidence is thin.

Being held after a judge orders release or reinstates probation is a different legal problem from being held before a hearing. Arrest needs reasonable grounds and revocation needs proof. Continued detention after an order of release needs a lawful basis of its own, such as another warrant, a hold from another county or a new charge.

The federal Eleventh Circuit, which covers Florida, recognizes a due process right "to be free from continued detention after the state should have known that they were entitled to release" (West v. Tillman, 496 F.3d 1321 (11th Cir. 2007)). The bar for a damages claim is high. A plaintiff must show deliberate indifference, and "Human error does not equal deliberate indifference." In West, a man stayed in custody from December 4 to December 27 after an order allowing his release, and the court still ruled for the jail officials. Alcocer v. Mills restated the test for "'over-detention,' or a continued detention after a right to release": the official knew of the risk, disregarded it, and did so with "more than mere negligence." It also held that detention on a new, separate basis after bond is a new seizure under the Fourth Amendment (906 F.3d 944 (11th Cir. 2018)). In Florida's own courts, the writ of habeas corpus "shall be grantable of right, freely and without cost" and is "returnable without delay" (Fla. Const. art. I, § 13).

Record Release delays have happened in Leon County recently, though not in connection with monitoring. In 2026 a failure in the county's new court software left people in jail after they should have been released. State Attorney Jack Campbell said: "They were supposed to be released from custody, but because of errors, they ended up spending multiple days," and "I think the longest I've heard now is six days in jail where they should have been released" (WTXL).

Not verified We found no public document recording a person reinstated to probation after a monitoring violation and then held for weeks. We cannot say how often it happens or why. Plausible reasons, each of which the records requests below are meant to test, include:

  • a separate hold from another county;
  • a delay in transmitting the order to the jail;
  • a wait to have equipment reinstalled; or
  • a wait for a residence to be approved before release.

These are hypotheses, not findings. In any individual case, the reason will appear in the docket and the jail's release records: when the order was signed, when the jail received it, and what hold, if any, was lodged.

Older people and a device you have to remember

What the research says, and what it does not

The reader's account stressed that the people involved were older. We found no Florida data on monitoring violations by age. The one controlled comparison of one-piece and two-piece equipment we found did address memory directly. In 2007, researchers at the University of California, Irvine, field-tested a two-piece system for California's parole agency, which at the time used one-piece units. They reported:

"Some parolees were leaving the tracking units, usually at home when they left for work. It was not necessarily clear how to distinguish between parolees who were legitimately forgetting the tracking unit and those who might be attempting to thwart supervision. One parolee in a focus group said he had a condition that impaired his memory, making it difficult for him to remember his tracking unit. Other parolees described adopting various strategies to help them remember their tracking unit (putting it near their keys, for example)." — Jannetta et al., Report on the Results of the CDCR Two-Piece GPS System Field Test (2007)

The same study found that one vendor allowed "a five-minute grace period for cuff leave alerts, which could not be modified," and the other allowed none. It recorded that "One parolee had his parole revoked as a consequence of having ten cuff leave alerts over a 30 day period." A national practitioners' guide published with the U.S. Bureau of Justice Assistance noted that some people "are more likely to have difficulty maintaining the equipment (e.g., charging the unit, keeping up with a two-piece unit)" (APPA, Offender Supervision with Electronic Technology, 2d ed. 2009).

In the willfulness standard, a documented memory impairment is relevant evidence. Douglas and King turn on the absence of a deliberate act, and Florida law excuses violations caused by "factors beyond his control."

How other systems handle it

Only jurisdictions and products with an authoritative source are listed

Florida is not typical. A 2016 report prepared for the National Institute of Justice by the Johns Hopkins University Applied Physics Laboratory found that "corrections agencies often prefer" single-piece systems "because there are fewer inventories to manage." It cited an industry expert's private estimate that "single-piece systems are used more often, by about a 3-to-1 margin." The same report noted that single-piece units "are easier to tamper with than multi-piece units," and that multi-piece systems "generally have more communications options and can offer greater security" (Heaton, GPS Monitoring Practices in Community Supervision, NIJ, Jan. 2016). That 3-to-1 figure is an estimate, not a count, and we found no current national survey by state.

Not every jurisdiction has moved away from a separate unit, and one-piece devices have their own problems. Each comparison below rests on the source cited. Many more states and counties probably use one-piece equipment than are listed here; we list only those we could document.

SystemEquipmentHow alerts are handledSource
Florida Dept. of CorrectionsTwo-piece (RTC) under renewal pricing; one-piece device in the contract's equipment scheduleOfficer must "immediately" investigate reports of noncompliance (statute). Vendor center handled most alarms in 2015. Written procedures not publicC2929; OPPAGA 15-16
Federal probation and pretrial services"A GPS tracker is affixed to the ankle"Officers "required to receive and respond to LM alerts 24 hours a day." For questionable points, "The officer must investigate the alert for noncompliance and analyze the GPS points" (satellites, speed, pattern)AO Location Monitoring Reference Guide (2020)
Georgia (statewide contract used by Corrections, Community Supervision, and Pardons and Parole)2016 award: "Single Piece (GPS)" as the primary category, to Satellite Tracking of People, with Buddi as backup. Multi-piece GPS was added that year as a separate category, awarded to 3MSupervision officer "reviews daily movement reports and is notified of all curfew and zone violations" (Parole Board). The award document does not describe alert responseGa. DOAS award recommendation, RFP SPD0000118 (Sept. 6, 2016); Ga. Parole Board
New Mexico Corrections DepartmentReported One-piece, per a reader. Not confirmed: department policy requires GPS for people on sex-offense supervision "if available" but does not name the deviceNot described in the published policies we readNMCD Policy CD-053200
Virginia Department of Corrections"a one-piece unit, as well as a 24-hour monitoring center"Not described on the pageVADOC
Texas paroleNot stated in the auditPolicy requires the officer to "investigate and resolve all device alerts and determine: Cause of alert. Whether the alert is a violation." Auditors found no case notes for 18% of sampled alertsTexas State Auditor 23-026 (2023)
California parole (2007 field test)One-piece in use, two-piece testedAgents' "biggest problem" with two-piece: the unit "is not physically attached." No definitive recommendation either wayUC Irvine (2007)

One-piece GPS ankle devices are widely sold. They include:

  • Allied Universal's AT1 (Allied Universal);
  • Attenti's "Solo3" (Attenti);
  • SuperCom's PureOne, a "one-piece tracking bracelet" using "LTE cellular communication" (SuperCom);
  • Track Group's XC5, a "One-piece GPS device" (Track Group).

In 2009 the practitioners' guide already reported that "several manufacturers have developed one-piece GPS units that are quickly replacing many of the two-piece models" (APPA 2009).

The trade-offs are real. The California study weighed "the longer battery life and relative ease of charging with the two-piece unit" against "the greater confidence that agents and supervisors feel having all the GPS equipment physically attached to the parolee through the one-piece unit." It also found strap-tamper alerts "more prevalent in the one-piece caseloads." A one-piece device is charged while worn, so the wearer must stay near an outlet. Florida's 2018 contract materials describe the two-piece RTC as the department's chosen upgrade. We found no public statement from the department explaining why it prefers two-piece equipment for most people (requested below).

What a jail stay costs the person held

Documented effects; no Florida study isolates monitoring-violation stays
  • Work. In Florida's own program, "Offenders and officers were almost unanimous in their assessment that the electronic tether is a serious detriment to offenders' ability to obtain employment and remain employed." That was before any arrest. When the unit lost its signal, people had to "walk the box for approximately 15 minutes until it picks up the satellite again" (Bales et al. 2010). We found no Florida figure on jobs lost during jail stays for monitoring violations.
  • Housing. The Vera Institute describes jail as bringing the "possible loss of custody of children, a job, or a place to live" (Vera, Incarceration's Front Door).
  • Money. People on state monitoring pay for it. The 2015 per diem was $5.25 (OPPAGA 15-16), and in King it was $4.50 a day. The order in Douglas recited a $1,050 replacement cost for the lost unit.
  • The sentence itself. The trial court in Douglas imposed 364 days in jail for a loss the appeals court found was not shown to be willful. The California field test recorded a parole revocation for repeated "cuff leave" alerts.
  • Scale. Nationally, technical supervision violations "account for nearly 1/4 of all state prison admissions" (CSG Justice Center). For Leon County's own pretrial monitoring program, a county official told the county's Public Safety Coordinating Council in May 2024 that "approximately 50% of electronic monitoring defendants are returned to custody for technical violations or new arrests." That figure covers the county's pretrial clients, not people on state probation.

Possible remedies

Labeled by what they are: existing law, available tools, or proposals

Existing law The hearing standard already protects against a violation finding. Under King, Channell and Douglas, a short, unintentional separation does not support revocation. The State must also prove its case with more than hearsay, which in practice means a monitoring-company witness or a properly founded business record (Channell). What the cases do not do is shorten the time before the hearing.

Existing law A prompt hearing and, after release is ordered, habeas. The statute requires a hearing "as soon as may be practicable" (§ 948.06(2)(d)). A person held after a court has ordered release may seek habeas corpus, which the Florida Constitution makes "returnable without delay." Federal over-detention claims exist, but the "deliberate indifference" standard in West and Alcocer makes damages hard to win.

Available tool Local administrative orders. Without any new legislation, the chief judge of the Second Circuit could do either of two things:

  • direct the department to use a "notification letter of a technical violation" instead of a warrant in appropriate cases (§ 948.06(1)(h)); or
  • add a brief, first, self-reported monitoring separation to the circuit's list of low-risk violations eligible for alternative sanctions (§ 948.06(9)(b)11).

Neither would help someone classed as a violent felony offender of special concern, because the statute excludes them.

Available tool Department procedure and equipment. The department could publish the following:

  • its grace period;
  • whether the bracelet's vibration warning is enabled;
  • the steps an officer must take before seeking a warrant on a separation alert. Federal and Texas policy both require the officer to determine the cause of an alert.

Its contract already includes a one-piece device. The current contract ends June 30, 2028, which makes the next procurement the natural point to revisit the default equipment.

Proposal Legislation. The no-bail rule in § 948.06(8)(d) applies to every alleged violation except nonpayment. The Legislature could set different rules for alleged equipment violations with no new offense alleged, for example a prompt hearing deadline or eligibility for release on conditions. We found no bill doing so in 2024–2026. The State's interest is stated in the Santos concurrence: "Probationers are not entitled to endanger public safety by violating the requirements of electronic monitoring." Any change would have to address that interest, along with the monitoring statute's purpose of locating people near crime scenes and prohibited areas (§ 948.11(6)).

Requests for records and comment

What has been sent, what has not, and where to send it
Status as of October 22, 2026: No public-records requests or requests for comment had been sent when this report was published. No one was interviewed. The requests below have been drafted and will be filed; this page will be updated with what comes back, including any refusals.

Florida Department of Corrections

Public Records Center: floridadoc.govqa.us (account help: 850-717-9774). Requests under Chapter 119, Florida Statutes, for existing records:

1. Any procedure, directive, training material or call-tree document in effect since January 1, 2023 governing response to "bracelet gone," out-of-range or tracking-device separation alerts, including grace periods, contact attempts and criteria for filing a violation report or seeking a warrant. If any portion is withheld under § 119.071 or another exemption, please cite the exemption and release the remainder.

2. The current contract C2929 with all amendments, and its technical specifications for the RTC and one-piece TD4 devices, including bracelet-to-unit range and alert settings.

3. Aggregate counts, statewide and for Circuit 2, for fiscal years 2023-24 through 2025-26: separation alerts; violation reports or affidavits citing electronic-monitoring separation; warrants issued; and use of technical-violation notification letters or alternative sanctions for monitoring violations. Counts only, no personal information.

4. Any record stating the department's reasons for using two-piece rather than one-piece equipment.

Leon County Sheriff's Office (jail)

Records Requests, Records Management Bureau, 3333 West Pensacola Street, Suite 100, Tallahassee, FL 32304, (850) 606-3317.

Aggregate data for 2024–2026 on people booked solely on violation-of-probation warrants: number, average and median length of stay, and the average interval between the court's release or reinstatement order and actual release, if maintained. Also the written procedure for processing release orders.

Leon County Clerk of Court and Second Judicial Circuit

Clerk records request. Court files in individual cases are public and can be searched by name through the Clerk's court records page.

Any administrative order of the Chief Judge of the Second Judicial Circuit establishing or defining the alternative sanctioning program under § 948.06(9), or directing use of technical-violation notification letters under § 948.06(1)(h).

Comment to be sought

  • Florida Department of Corrections, Office of Community Corrections (via the department's communications office);
  • Allied Universal Electronic Monitoring;
  • Office of the Public Defender, Second Judicial Circuit (flpd2.com, Leon County Courthouse, 301 S. Monroe St., Suite 401);
  • Office of the State Attorney, Second Judicial Circuit;
  • ACLU of Florida;
  • Florida Action Committee.

None had been contacted at publication.

What we could not verify

Open questions. This page will be updated when an official answer exists.
  • The four reported cases. Not independently verified: no names, dockets, dates or detention periods have been examined.
  • How often separation alerts lead to arrest, statewide or in Leon County. No published data separates monitoring violations from other technical violations.
  • Whether anyone has been held for weeks after reinstatement, and if so, why. No public record of this sequence was found.
  • The department's written alert-response procedure and whether it distinguishes accidental separation from concealment. Not public; the Auditor General withheld details.
  • The bracelet-to-unit range and alert timing on the RTC as configured in Florida, and whether the vibration warning is on. The only description found is testimony in one Bay County case.
  • How many people under state supervision wear the one-piece device listed in the contract, and why the department defaults to two-piece.
  • Whether the Second Circuit has an administrative order on alternative sanctions or notification letters, and whether it covers monitoring violations.
  • Florida cases on preliminary hearings for probationers, and the current text of Fla. R. Crim. P. 3.790 and 3.131. We read the rules in an earlier compilation.
  • Which equipment New Mexico and Georgia use today. A reader reports New Mexico uses a single unit; its published policies do not say. Georgia's documented single-piece award dates from 2016, and the contract that replaced it, if any, was not found.
  • The outcome of a 2015 federal lawsuit alleging that the GPS equipment used by Leon County's pretrial and county probation programs was "faulty and result[ed] in unintended violations." Known to us only through a Florida Action Committee repost, and concerning the county program, not the state's. We found no lawsuit, class action, inspector-general report or bill directly challenging the state's two-piece requirement.

If you have a court order, an affidavit, a jail release record or a written answer from an agency on any of these, send it to us. We publish only what we can check against the source. Please do not send private medical or family details.

Short answers

General information, not legal advice. Each points back to the sourced findings above.
Can someone be arrested for leaving the box behind for a few minutes?

Yes. An officer may arrest on "reasonable grounds to believe" a material violation occurred, before anyone decides whether it was willful. Whether it is a violation is a separate question for the judge, and the First District has held that a brief, unintentional separation is not enough. See Three stages and The case law.

Why can't they get bond?

For someone classed as a violent felony offender of special concern, which includes many people on probation for listed sexual battery, lewd or lascivious and child-pornography offenses committed since 2007, the statute says they "shall remain in custody" until the violation is resolved. For other registrants a judge must first find them "not a danger to the public." In Leon County a probation warrant that is silent on bond means no bond. See Why the wait.

What records matter if this happens to someone I know?

The violation affidavit and warrant; the monitoring report for the alert, including its start and end times; any call log from the monitoring center; earlier alerts, if any; the court docket showing first appearance, hearing dates and the final order; and the jail's booking and release times. In Florida, court files are public through the Clerk. A lawyer can use this to argue the points in The case law. This is general information, not legal advice.

Does Douglas mean losing the unit is never a violation?

No. It held that one record lacked evidence of a willful act. Repeated failures, or a known rule deliberately ignored, have supported violations, as in Soliz and the Santos affirmance.

Sources

Primary documents, read October 21–22, 2026 unless noted

Statutes, rules and orders

Court opinions

Contracts, audits and agency documents

Research

Vendor materials

News and secondary sources

Related: Registry Wire: In Depth · Case Law Library · Florida statutes in LawLookup

Legal Disclaimer

This report summarizes Florida statutes, court decisions, public contracts and agency documents for general education. It is not legal advice. Whether a particular person can be released, what a court is likely to find, and what equipment rules apply depend on the person's offense, the date it was committed, the court's order and the department's instructions. Anyone facing a violation of probation should speak with a lawyer licensed in Florida, such as the assigned public defender.