CLAUDE R. CAMPBELL, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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Claude Campbell appealed the summary denial of his post-conviction motion to withdraw his guilty plea, claiming he was under the influence of heavy medication when he entered the plea and therefore lacked full understanding of the consequences. The appellate court reversed and remanded, finding the record did not conclusively refute Campbell's allegations and that a hearing was necessary.
The court held that the record did not sufficiently overcome Campbell's allegations to permit summary denial of his motion. Remanding for a hearing, the court concluded that Campbell's apparent lack of articulateness, questions about his competency, and the undisputed fact of his medication use meant the plea transcript alone was insufficient to deny relief.
[1] A guilty plea may be withdrawn if it was not entered with a full understanding of the consequences due to the defendant's medication.
[2] A motion for post-conviction relief alleging a plea was not understood due to medication cannot be summarily denied if the record does not conclusively refute the allegat…
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Join FLexlaw to unlock all legal intelligence“where claims such as this have been made the record must conclusively refute the defendant's allegations before the court may deny the motion without a hearing”
Establishes the legal standard that summary denial of post-conviction motions alleging medication-impaired understanding requires conclusive refutation by the record
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceCampbell entered a guilty plea after a brief competency hearing in which the trial court found him competent. Defense counsel noted that Campbell was …
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SANDERLIN, Judge.
Claude Campbell appeals the summary denial of his motion for post-conviction relief.
Campbell’s motion states that his guilty plea was not entered with a full understanding of the consequences because he was under the influence of a heavy dose of medication at the time of the plea. If true, this could constitute grounds to withdraw the plea. Stinyard v. State, 476 So. 2d 277 (Fla. 2d DCA 1985). We have held that where claims such as this have been made the record must conclusively refute the defendant’s allegations before the court may deny the motion without a hearing. Gunn v. State, 379 So. 2d 431 (Fla. 2d DCA 1980).
In the instant case, the trial court attached a transcript of the plea colloquy to its order denying Campbell’s motion. Prior to accepting the plea the court conducted a brief competency hearing, then, having found Campbell competent to proceed, discussed the plea agreement with the attorneys. Defense counsel indicated “one slight problem” and asked the court to “rule on it,” referring to the fact that Campbell was “under medication.” Campbell was then brought before the court and questioned. As in the Gunn case, the colloquy generally was thorough, though Campbell only “replie[d] affirmatively” to most of the questions. Then the court asked Campbell if his medication was “hampering [his] ability to understand and appreciate what is going on here today.” Campbell first said he did not know, but when the court asked if he understood, he replied, “Yeah.”
We recognize that the trial court was in the best position to observe Campbell’s demeanor and level of awareness at the time of the plea. However, we must conclude that the record before us does not sufficiently overcome Campbell’s allegations to permit summary denial of his motion. In light of the question of Campbell’s competency, his apparent lack of articulateness during the colloquy, and the undisputed fact that he was drugged to some extent, we are not persuaded by the plea transcript alone that Campbell is not entitled to relief, particularly when it is compared with the extensive inquiry in Onnestad v. State, 404 So. 2d 403 (Fla. 5th DCA 1981). Accordingly, we reverse and remand this case to the trial court for further proceedings consistent with this opinion. Of course, if a hearing is held on Campbell’s motion, his allegations are subject to rebuttal by competent evidence. Baker v. State, 427 So. 2d 1141 (Fla. 2d DCA 1983).
The remaining grounds raised in Campbell’s motion are without merit, and the trial court properly denied relief on those grounds.
LEHAN, A.C.J., and FRANK, J., concur.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By (12 total)
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Rivera v. State, 746 So. 2d 542 (Fla. 2d DCA 1999)…also indicate Rivera experienced auditory hallucinations the entire time he was in detention. We find that Rivera’s motion states a facially sufficient claim for relief. See Reutter v. State, 590 So. 2d 1133 (Fla. 2d DCA 1992); Campbell v. State, 488 So. 2d 592 (Fla. 2d DCA 1986) (citing Stinyard v. State, 476 So. 2d 277 (Fla. 2d DCA 1985)). The trial court denied the motion, relying, in part, on the plea form signed by Rivera and the transcript of the plea colloquy. These attachments do not refute Rivera’…
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Reutter v. State, 590 So. 2d 1133 (Fla. 2d DCA 1992)…tachment to the trial court’s summary denial of Reutter’s motion does not conclusively refute these allegations. Accordingly, we reverse the summary denial of these allegations in the motion and remand for further proceedings. See Campbell v. State, 488 So. 2d 592 (Fla. 2d DCA 1986); Gunn v. State, 379 So. 2d 431 (Fla. 2d DCA 1980); Derks v. State, 477 So. 2d 23 (Fla. 1st DCA 1985). On remand, unless the case files and records conclusively show that Reutter is not entitled to relief, the trial court shall ord…
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Savage v. State, 530 So. 2d 1077 (Fla. 1st DCA 1988)…4). Nevertheless, the court will also consider evidence subsequent to the plea or trial, when it appears the record does not satisfactorily resolve the allegations of incompetency. Blanco v. Wainwright, 507 So. 2d 1377 (Fla.1987); Campbell v. State, 488 So. 2d 592 (Fla. 2d DCA 1986); Livingston v. State, 383 So. 2d 947 (Fla. 2d DCA 1980). In circumstances somewhat analogous to those present in the instant case, in Campbell v. State, supra, the court found an evidentiary hearing was required. In Campbell, the…
Previewing 3 of 12 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Onnestad v. State, 404 So. 2d 403 (Fla. 5th DCA 1981)
- Gunn v. State, 379 So. 2d 431 (Fla. 2d DCA 1980)
- Stinyard v. State, 476 So. 2d 277 (Fla. 2d DCA 1985)
- Baker v. State, 427 So. 2d 1141 (Fla. 2d DCA 1983)