DAVID A. SMITH
v.
STATE OF FLORIDA
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David A. Smith appeals a trial court's denial of his postconviction relief motion challenging the voluntariness of his guilty plea to capital sexual battery. Smith claimed he did not adequately understand the elements of the crime and the State's ability to prove penetration. The appellate court affirmed the trial court's finding that Smith failed to meet his burden of showing the plea was involuntary.
The trial court properly denied Smith's postconviction relief motion because Smith failed to meet his burden of showing his guilty plea was not knowingly and voluntarily entered. The trial court's findings were supported by competent, substantial evidence, including the credible testimony of the trial defense counsel.
[1] A defendant challenging a guilty plea via a motion for postconviction relief bears the burden of proving the plea was not knowingly and voluntarily entered.
[2] A trial court judge presiding over a postconviction evidentiary hearing is in a superior position to assess witness credibility and make factual findings.
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Join FLexlaw to unlock all legal intelligence“A defendant challenging a guilty plea with a rule 3.850 motion has the burden of showing his plea was not knowingly and voluntarily entered.”
Establishes the legal standard and burden of proof for postconviction challenges to guilty pleas
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Join FLexlaw to unlock all legal intelligenceSmith entered a guilty plea to capital sexual battery. He subsequently filed a postconviction relief motion under Florida Rule of Criminal Procedure 3…
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LONG, J.
Smith appeals an order denying his motion for postconviction relief pursuant to Florida Rule of Criminal Procedure 3.850. He entered a guilty plea he now claims was involuntary. He contends he did not adequately comprehend the elements of capital sexual battery and the ability of the State to prove the element of penetration.
A defendant challenging a guilty plea with a rule 3.850 motion has the burden of showing his plea was not knowingly and voluntarily entered. See Mikenas v. State, 460 So. 2d 359, 361 (Fla. 1984). The postconviction trial court found Smith failed to meet this burden. And those findings were supported by competent, substantial evidence.
After an evidentiary hearing on the issue, the trial court denied Smith’s request for relief. The court credited the testimony of the trial defense counsel who refuted Smith’s claims. A trial court judge presiding over a rule 3.850 evidentiary hearing has a superior vantage point to assess the credibility of witnesses and make factual findings. Porter v. State, 788 So. 2d 917, 923 (Fla. 2001). So long as the trial judge’s findings are supported by competent, substantial evidence, an appellate court “will not substitute its judgment for that of the trial judge on questions of fact and, likewise, on the credibility of the witnesses and the weight to be given to the evidence by the trial court.” Id.
AFFIRMED.
LEWIS and TANENBAUM, JJ., concur. _____________________________
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Porter v. State, 788 So. 2d 917 (Fla. 2001)
- Mikenas v. State, 460 So. 2d 359 (Fla. 1984)