Negligence or ineptitude does not support a finding of a willful and substantial violation. Rousey v. State, 226 So. 3d 1015, 1017 (Fla. 2d DCA 2017); see also Selig v. State, 112 So. 3d 746, 749 (Fla. 2d DCA 2013) ("A defendant’s failure to comply with a probation condition is not willful where his conduct shows a reasonable, good faith attempt to comply and factors beyond his control, rather than a deliberate act of misconduct, caused his noncompliance." (quoting Soto v. State, 727 So. 2d 1044, 1046 (Fla. 2d DCA 1999) (internal alterations omitted))).

Williams argues the State failed to produce competent, substantial evidence that he willfully and substantially violated curfew. He relies on several cases to support his contention that his conduct was merely the product of ineptitude or negligence: Rousey v. State , 226 So. 3d 1015 (Fla. 2d DCA 2017) ; McCray v. State , 754 So. 2d 776 (Fla. 3d DCA 2000) ; and Stevens v. State , 599 So. 2d 254 (Fla. 3d DCA 1992). First, competent, substantial evidence supports the trial court's findings.

First, he cites cases where a probationer obtained, or at least sought, permission for the actions leading up to the violation. See Rousey v. State, 226 So. 3d 1015, 1016 (Fla. 2d DCA 2017) (officer gave permission for probationer to go to cell phone store); Hugan v. State, 190 So. 3d 210, 211 (Fla. 2d DCA 2016) (probationer called officer to seek permission to take extra shift); Thomas v. State, 672 So. 2d 587, 588 (Fla. 4th DCA 1996) (job interview was approved). By contrast here, Mr. Timke did not attempt to coordinate with his probation officer in any way—neither before heading downtown nor after it became clear that he would not make curfew.

Cusamano v. State, 298 So. 3d 1266, 1267 (Fla. 2d DCA 2020) (quoting Savage v. State, 120 So. 3d 619, 621 (Fla. 2d DCA 2013) ). "[A] violation of supervision is willful only where the defendant fails to make reasonable efforts to comply with the alleged violated condition." Rousey v. State, 226 So. 3d 1015, 1017 (Fla. 2d DCA 2017). And "[a] revocation based on the failure to complete a rehabilitation program must be shown to be the probationer's fault."