Our courts have determined that "[e]lectrical components ... are subject to accelerated obsolescence because manufacturers are constantly releasing new, improved technology at lower prices." Y.R. v. State, 226 So. 3d 1008, 1009 n.2 (Fla. 3d DCA 2017) (quoting Lucky v. State, 25 So. 3d 691, 692 (Fla. 4th DCA 2010) ). However, here, the recency of obtainment, along with the condition and utility of the telephone, supported the trial court's reasoned determination that any depreciation in value was de minimis.
For this reason, purchase price alone is generally insufficient to establish the value of such property in theft cases." Y.R. v. State, 226 So. 3d 1008, 1009 n.2 (Fla. 3d DCA 2017) (quoting Lucky v. State, 25 So. 3d 691, 692 (Fla. 4th DCA 2010)). Nonetheless, "[v]alue may be established by direct testimony of fair market value or through evidence of the original market cost of the property, the manner in which the items were used, the condition and quality of the items, and the percentage of depreciation of the items since their purchase."
On remand, the trial court shall conduct a new disposition hearing to reconsider—in light of the reduced offense—its prior imposition of probation for an indefinite period not to exceed D.J.S.'s nineteenth birthday; D.J.S. has a right to be present at the hearing. See Y.R. v. State, 226 So.3d 1008, 1009 (Fla. 3d DCA 2017).Affirmed in part, reversed in part, and remanded with instructions.