STANLEY H. DAVIS, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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Davis appealed the trial court's denial of his post-conviction relief motion challenging the voluntariness of his guilty plea. The appellate court reversed and remanded, holding that the trial court must conduct an evidentiary hearing or make findings from the record to determine whether Davis's plea was voluntary, as the written plea agreement alone cannot establish voluntariness.
The appellate court held that the written plea agreement alone is insufficient to demonstrate the voluntariness of a guilty plea, and the trial court must either summarily deny the motion while attaching portions of the record conclusively showing voluntariness, or conduct an evidentiary hearing to determine whether the plea was voluntary.
[1] A guilty plea is rendered involuntary and unlawful if induced by coercion or misrepresentations by law enforcement.
[2] A written plea agreement, while supporting the denial of post-conviction relief, does not conclusively establish the voluntariness of a guilty plea on its own.
Previewing 2 of 4 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“The written plea agreement, if voluntarily entered, would support the trial court's denial of defendant's motion. However, we cannot determine from the written plea agreement alone whether defendant voluntarily pled guilty.”
Establishes the central holding that the existence of a written plea agreement is insufficient by itself to establish voluntariness of the plea.
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceDavis entered into a written plea agreement and pled guilty to multiple felonies including armed robbery with a firearm, second-degree arson, grand th…
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SCHEB, Judge.
This appeal is from the trial court’s denial of a motion seeking post-conviction relief under Florida Rule of Criminal Procedure 3.850.
Pursuant to a written plea agreement, defendant pled guilty to several offenses, including armed robbery with a firearm, second-degree arson, several counts of grand theft and burglary of a structure, battery on a law enforcement officer, resisting arrest with violence, possession of a firearm during commission of a felony, and unauthorized use of a driver’s license. The trial court sentenced him to twenty-five years in prison under the agreement’s terms.
Defendant listed several allegations in his motion. All his allegations hinge on his contention that his guilty plea was unlawfully induced and not made voluntarily. He argued that a police detective coerced him into his plea by making certain statements to him. Defendant claimed the police officer said that he was best friends with the judge and would make sure defendant received a ninety-nine year prison sentence if the defendant did not plead guilty and testify against another person.
The trial court denied defendant’s motion for post-conviction relief, because all his grounds in the motion were moot due to the written plea agreement. The court attached a copy of the written plea agreement to the order. The written plea agreement, if voluntarily entered, would support the trial court’s denial of defendant’s motion. However, we cannot determine from the written plea agreement alone whether defendant voluntarily pled guilty.
Accordingly, we reverse the denial of defendant’s motion and remand the case to the trial court. On remand the court may summarily deny the motion as to the allegations specified, attaching to its order those portions of the record conclusively showing that defendant voluntarily pled guilty, or hold an evidentiary hearing to determine defendant’s plea was voluntary. See Fla.R.Crim.P. 3.850. See also Gurchick v. State, 428 So. 2d 738 (Fla. 2d DCA 1983); Jones v. State, 421 So. 2d 55 (Fla. 1st DCA 1982); and Van Bever v. State, 405 So. 2d 474 (Fla. 5th DCA 1981). If the trial court determines that defendant’s plea was involuntary, then it should review the defendant’s other allegations. To obtain further review, defendant must appeal the new ruling of the trial court.
GRIMES, A.C.J., and FRANK, J., concur.
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Citator
Cited By
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McELVANE v. State, 553 So. 2d 321 (Fla. 1st DCA 1989)…was informed of his rights, knew the maximum penalty, knowingly waived the jury trial, and pled freely and voluntarily.” Id. at 561. We note a different result may have been reached by the Second District in light of its opinion in Davis v. State, 468 So. 2d 443 (Fla. 2d DCA 1985) in which it reversed and remanded the trial court’s denial of a 3.850 motion where the trial court had denied the motion stating that all the grounds in the motion were moot due to the attached, written plea agreement. The Second…
Authorities Cited
- Jones v. State, 421 So. 2d 55 (Fla. 1st DCA 1982)
- VAN Bever v. State, 405 So. 2d 474 (Fla. 5th DCA 1981)
- Reifsnyder v. State, 428 So. 2d 738 (Fla. 2d DCA 1983)