SAMUEL WILLIAMS, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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Williams appeals his guilty plea conviction for drug delivery and resisting arrest with violence, challenging whether the trial court adequately established a factual basis for the plea. The appellate court reversed, finding that when the defendant denied the fighting element of the resisting arrest charge, the trial court was required to conduct further inquiry before accepting the plea.
The trial court's inquiry was insufficient because when the defendant denied fighting—an element of the resisting arrest charge—the court was obligated to conduct further inquiry to establish a factual basis for that element. The defendant met his burden of demonstrating prejudice by raising the possibility of a defense during his response.
[1] A trial court must satisfy itself that there is a factual basis for a guilty plea before accepting it.
[2] A factual basis for a guilty plea may be established by evidence, testimony, a proffer, statements by counsel or the defendant, or reference to the record.
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Join FLexlaw to unlock all legal intelligence“Before accepting a guilty plea, a trial court is required to satisfy itself that there is a factual basis for the plea.”
Establishes the fundamental requirement for accepting guilty pleas under Florida law
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Join FLexlaw to unlock all legal intelligenceWilliams was charged with unlawfully delivering cocaine to Keven Kin on July 12 in Broward County, Florida, and with resisting arrest with violence ag…
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STONE, Judge.
The sole issue on appeal is whether the trial court erred in accepting a plea of guilty without sufficient support in the record that there was a factual basis for the plea.
The following colloquy occurred between the court and the defendant:
THE COURT: When you plead guilty to this charge, Mr. Williams, you’re admitting that on the 12th of July of last year in Broward County, Florida, you unlawfully delivered to Keven Kin a controlled substance, to wit, cocaine contrary to the law. Do you understand that?
MR. WILLIAMS: Yes, sir. THE COURT: Also that you resisted arrest with violence, that you unlawfully, knowingly and willfully resisted, obstructed or opposed him by offering or doing violence to him, by fighting with a duly qualified law enforcement officer of the Oakland Park Police Department in the lawful execution of a legal duty being performed by the officer, to wit, arresting you contrary to the law.
MR. WILLIAMS: I didn’t fight.
THE COURT: That’s what you’re admitting to by pleading guilty. Do you understand that?
MR. WILLIAMS: Yes, sir, I do.
The defendant asserts that a more extensive inquiry was required once he denied the allegation of fighting. There was no additional evidence or proffer of evidence by either the state or the defense.
Before accepting a guilty plea, a trial court is required to satisfy itself that there is a factual basis for the plea. Williams v. State, 316 So. 2d 267 (Fla.1975); Meredith v. State, 508 So. 2d 473 (Fla. 4th DCA 1987); Dydek v. State, 400 So. 2d 1255 (Fla. 2d DCA 1981); Fla.R.Crim.P. 3.172(a). Generally, the rule may be complied with by receiving evidence, testimony, a proffer of evidence, statements by counsel or the defendant, or reference to the record sufficient to satisfy the court that there is evidence to convict on each element of the charge. See Williams v. State.
The failure of the court to make a complete inquiry, or to receive a complete proffer, will generally not result in reversal on appeal without a corresponding showing of prejudice. See State v. Kendrick, 336 So. 2d 353 (Fla.1976); Williams v. State, 316 So. 2d 267 (Fla.1975); Fitzpatrick v. State, 414 So. 2d 1121 (Fla. 1st DCA 1982). However, where the defendant raises the possibility of a defense in the course of his response, the potential prejudice is considered apparent and a further inquiry by the trial court is necessary. See State v. Kendrick, 336 So. 2d 353 (Fla.1976); State v. Lyles, 316 So. 2d 277 (Fla.1975). See also Monroe v. State, 318 So. 2d 571 (Fla. 4th DCA 1975); Miles v. State, 338 So. 2d 547 (Fla. 3d DCA 1976).
We conclude that the court’s inquiry here was insufficient, and that appellant has met his burden of demonstrating prejudice. The information alleged that the defendant committed the crime of resisting arrest by fighting. At the plea hearing the defendant denied fighting, and no further inquiry or factual recitation occurred. Therefore, we reverse and remand the judgment and sentence so that the trial court may conduct a further inquiry into the factual basis for the plea.
WALDEN, J„ and WESSEL, JOHN D.,. Associate Judge, concur.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By (11 total)
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Bell v. State, 589 So. 2d 1374 (Fla. 1st DCA 1991)…uilty to count four, Bell admitted to personally carrying a firearm during the robbery. The trial court was therefore required at the plea hearing to determine whether there was a factual basis for the minimum-mandatory sentence. Williams v. State, 534 So. 2d 929 (Fla.1988). The requirement that a trial court ascertain the factual basis for a guilty plea is intended to preclude an unwitting admission of guilt for a crime the defendant did not in fact commit. Shannon v. State, 406 So. 2d 87, 88 (Fla. 1st DCA…1 / 2
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Gust v. State, 558 So. 2d 450 (Fla. 1st DCA 1990)…ied with by receiving evidence, testimony, a proffer of evidence, statements by counsel or the defendant, or reference to the record sufficient to satisfy the court that there is evidence to convict on each element of the charge.” Williams v. State, 534 So. 2d 929, 930 (Fla. 4th DCA 1988). If, however, the court fails to make a complete inquiry or to receive a complete proffer, its failure will not generally result in reversal without a corresponding showing of prejudice. Id. The trial court below denied appe…
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Lennard Lapoint Jenkins v. State, 747 So. 2d 997 (Fla. 5th DCA 1999)…waive by non-argument the legislative requirement that a weapon as contemplated by the robbery statute “be carried.” A defendant cannot even plead to an offense until the State has proffered proof of each element of the crime. See Williams v. State, 534 So. 2d 929, 930 (Fla. 4th DCA 1988). Can he preclude a proper judicial statutory interpretation at trial, an interpretation which would make the difference between a second degree felony and a first degree felony, by non-argument? We have learned by experience…
Previewing 3 of 11 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Williams v. State, 316 So. 2d 267 (Fla. 1975)
- State v. Lyles, 316 So. 2d 277 (Fla. 1975)
- Dydek v. State, 400 So. 2d 1255 (Fla. 2d DCA 1981)
- State v. Bunyan L. Kendrick, Jr., 336 So. 2d 353 (Fla. 1976)
- Borri v. Siverson, 336 So. 2d 353 (Fla. 1976)
- Monroe v. State, 318 So. 2d 571 (Fla. 4th DCA 1975)
- Fitzpatrick v. State, 414 So. 2d 1121 (Fla. 1st DCA 1982)
- Miles v. State, 338 So. 2d 547 (Fla. 3d DCA 1976)
- Meredith v. State, 508 So. 2d 473 (Fla. 4th DCA 1987)
- State v. Saunders, 508 So. 2d 473 (Fla. 4th DCA 1987)