THE STATE OF FLORIDA, APPELLANT,
v.
CRYSTAL FRAZIER AND CHRISTOPHER FRAZIER, APPELLEES
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The State of Florida appealed a trial court's dismissal of aggravated battery charges against Crystal and Christopher Frazier after prosecutors breached a plea agreement in which they promised to nolle prosse those charges in exchange for their aunt Patricia Frazier's guilty plea to the lesser offense of battery. The appellate court affirmed the dismissal, holding that the younger Fraziers were intended third-party beneficiaries of the plea agreement and entitled to enforce it against the prosecution.
The court held that Crystal and Christopher Frazier were intended third-party beneficiaries of the plea agreement with their aunt and were entitled to enforce it. The prosecution, having secured the benefit of Patricia Frazier's guilty plea, must be held to the detriment of the agreement and cannot unilaterally breach it by continuing prosecution of the younger Fraziers.
[1] Plea agreements are subject to the rules of contract law.
[2] Individuals who are intended third-party beneficiaries of a plea agreement are entitled to enforce that agreement.
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“even if neutral principles of law did not, as they do, require this result, the state, above all parties, must keep its word”
Establishes the fundamental principle that the state has an affirmative duty to honor its contractual commitments in plea agreements, independent of strict legal requirements.
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Join FLexlaw to unlock all legal intelligencePatricia Frazier, her niece Crystal Frazier, and her nephew Christopher Frazier were all charged with aggravated battery arising from a single inciden…
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SCHWARTZ, Chief Judge.
Patricia Frazier and her niece and nephew, Crystal and Christopher Frazier, were all charged with aggravated battery arising from a single incident. In return for her plea of guilty to the lesser offense of battery, the prosecution agreed and specifically announced in open court when her plea was taken that the eases against her niece and nephew would be nolle prossed. When the state attempted to renege on the agreement and continue the prosecution against them, the trial court ordered the cases dismissed and the state has taken this appeal. We affirm.
Applying the rules of contract law applicable to plea agreements, like all others, see Clark v. State, 651 So. 2d 1309 (Fla. 3d DCA 1995), review denied, 660 So. 2d 712 (Fla.1995); Novaton v. State, 610 So. 2d 726 (Fla. 3d DCA 1992), approved, 634 So. 2d 607 (Fla.1994); Madrigal v. State, 545 So. 2d 392 (Fla. 3d DCA 1989), it is clear that the younger Fraziers were intended third party beneficiaries, Technicable Video Sys., Inc. v. Americable of Greater Miami, Ltd., 479 So. 2d 810 (Fla. 3d DCA 1985), of the plea agreement with their aunt. See United States v. Nuckols, 606 F. 2d 566, 569 (5th Cir.1979)(“[W]e see no intrinsic constitutional infirmity in broadening plea negotiations so as to permit third party beneficiaries.... Recognizing, however, that threats to prosecute third persons can carry leverage wholly unrelated to the validity of the underlying charge, we think that prosecutors who choose to use that technique must observe a high standard of good faith.”); Hamlet v. State, 68 Md.App. 553, 514 A. 2d 492 (1986).
As such, they were eminently entitled to enforce that agreement. Even more obviously, the prosecution, having reaped the benefits of the agreement by securing the guilty plea, must be held to its detriments, see Novaton, 610 So. 2d at 728; Madrigal, 545 So. 2d at 392, including submission to the order below specifically enforcing the undertaking. Santobello v. New York, 404 U.S. 257, 92 S.Ct. 495, 30 L.Ed.2d 427 (1971); Hunt v. State, 613 So. 2d 893 (Fla.1992); Buffa v. State, 641 So. 2d 474 (Fla. 3d DCA 1994).
Finally, even if neutral principles of law did not, as they do, require this result, the state, above all parties, must keep its word. See State v. Hargis, 328 So. 2d 479, 481 (Fla. 1st DCA 1976) (Rawls, J., dissenting). Its attempts to convince the lower court and this one that it should be allowed to break it are unseemly and unworthy.
Affirmed.
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Cited By (27 total)
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Garcia v. State, 722 So. 2d 905 (Fla. 3d DCA 1998)…ce of law is an illegal condition of probation. Defendant argues that the court lacks jurisdiction to prohibit him from practicing law. A plea agreement is a contract and the rules of contract law are applicable to plea agreements. State v. Frazier, 697 So. 2d 944 (Fla. 3d DCA 1997). A party may waive any right to which he is legally entitled under the Constitution, a statute, or a contract. State, Department of Health & Rehabilitative Services v. E.D.S. Federal Corporation, 631 So. 2d 353 (Fla. 1st DCA 1994)…
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State v. Warner, 721 So. 2d 767 (Fla. 4th DCA 1998)…connotes an “agreement or contract.” American Heritage Dictionary 107 (1981). Unlike trial courts, who are not bound to a specific sentence, agreements between the prosecutor and the defendant can be enforceable under contract law. State v. Frazier, 697 So. 2d 944, 945 (Fla. 3d DCA 1997)(state required to nolle pross charges against third persons per plea agreement); State v. Davis, 188 So. 2d 24 (Fla. 2d DCA 1966)(enforcing prosecutor’s agreement not to prosecute if defendant passed polygraph test). In Davi…
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State v. Swett, 772 So. 2d 48 (Fla. 5th DCA 2000)…rative portion of his sentence to that substantially below the range contained in the plea agreement. The state points out that a plea agreement is a contract between the state, represented by the prosecutor, and the defendant. See State v. Frazier, 697 So. 2d 944 (Fla. 3d DCA 1997), State v. Warner, 721 So. 2d 767 (Fla. 4th DCA 1998), approved, 762 So. 2d 507 (Fla.2000). The state asserts that where a guilty or nolo plea is part of a quid pro quo whereby the state has agreed to drop or reduce a charge, the s…
Previewing 3 of 27 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited (11 total)
- Santobello v. New York, 404 U.S. 257 (U.S. 1971)
- Novaton v. State, 634 So. 2d 607 (Fla. 1994)
- Domingo Antonio Madrigal v. State, 545 So. 2d 392 (Fla. 3d DCA 1989)
- Deidre Michelle Hunt v. State, 613 So. 2d 893 (Fla. 1992)
- United States v. Nuckols, 606 F.2d 566 (5th Cir. 1979)
- Gonzalez Eng'g, Inc. v. Miami Pump & Supply Co., Inc., 641 So. 2d 474 (Fla. 3d DCA 1994)
- Novaton v. State, 610 So. 2d 726 (Fla. 3d DCA 1992)
- Technicable Video Sys., Inc. v. Americable OF Greater Miami, Ltd., 479 So. 2d 810 (Fla. 3d DCA 1985)
- Clark v. State, 651 So. 2d 1309 (Fla. 3d DCA 1995)
- Kenneth Hemmerle and wife v. DeSOTO Nat'l Bank OF Arcadia, 328 So. 2d 479 (Fla. 2d DCA 1976)