STATE OF FLORIDA, APPELLANT,
v.
STEVEN KLEIN, APPELLEE
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The State appealed a trial court order granting Klein's motion for specific performance of a plea agreement and dismissing a commitment petition under Florida's Jimmy Ryce Act (sexually violent predator law). The appellate court reversed, holding that involuntary civil commitments under the Ryce Act are separate from criminal proceedings and thus not governed by criminal plea agreements.
A plea agreement in a criminal case has no bearing on a subsequent involuntary civil commitment under the Jimmy Ryce Act, because the commitment proceeding is a separate civil action, not a continuation of criminal punishment. Therefore, Klein's plea agreement cannot be specifically enforced to prevent his commitment as a sexually violent predator.
[1] An involuntary commitment under the Jimmy Ryce Act is not considered continued punishment for a criminal offense.
[2] A commitment proceeding under the Jimmy Ryce Act is separate from the underlying criminal action.
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“an involuntary commitment under the Jimmy Ryce Act is not considered to be a continued punishment for a criminal offense. Rather, the court reasoned, a commitment proceeding is separate from the criminal action that was based on the individual's sexually violent offense.”
Establishes that Ryce Act commitments are civil and independent from criminal proceedings, overturning the trial court's reasoning.
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Join FLexlaw to unlock all legal intelligenceSteven Klein was found by a jury to be a sexually violent predator and committed to the custody of the Department of Children and Families under the J…
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MONACO, J.
After a jury trial finding the appellee, Steven Klein, to be a sexually violent predator, he was committed to the custody of the Department of Children and Families in accordance with the requirements of the Jimmy Ryce Act, section 394.910, et seq., Florida Statutes (2001). Thereafter, the trial court granted Klein’s motion for specific performance of a plea agreement that he entered into in the underlying criminal case that led to the Ryce Act proceeding. The State of Florida appeals an order of the trial court that granted Klein’s motion for specific performance of the plea agreement in reliance on the case of Harris v. State, 27 Fla. L. Weekly D946, — So. 2d —, 2002 WL 731699 (Fla. 1st DCA Apr.26, 2002). We reverse.
Since the entry of the order being appealed in this case, the Supreme Court of Florida has held in Murray v. Regier, 27 Fla. L. Weekly S1008, — So. 2d —, 2002 WL 31728885 (Fla. Dec. 5, 2002), that an involuntary commitment under the Jimmy Ryce Act is not considered to be a continued punishment for a criminal offense. Rather, the court reasoned, a commitment proceeding is separate from the criminal action that was based on the individual’s sexually violent offense. Thus, the court concluded that “any bargain that a defendant may strike in a plea agreement in a criminal case would have no bearing on a subsequent involuntary civil commitment for control, care, and treatment.” Id. at S1010, — So. 2d at —. See also Sandillo v. State, 842 So. 2d 1018 (Fla. 5th DCA 2003); Ritchie v. State, 842 So. 2d 234 (Fla. 5th DCA 2003); Satz v. Runion, 838 So. 2d 689 (Fla. 4th DCA 2003).
Accordingly, the order of the trial court granting Klein’s motion for specific performance of his plea agreement, dismissing the petition for involuntary commitment, and ordering Klein’s release is reversed and vacated, and the case is remanded with directions to deny Klein’s motion.
REVERSED, VACATED AND REMANDED.
SAWAYA, C.J., and ORFINGER, J., concur.
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Citator
Authorities Cited
- Murray v. Regier, 872 So. 2d 217 (Fla. 2002)
- Satz v. Runion, 838 So. 2d 689 (Fla. 4th DCA 2003)
- Sandillo v. State, 842 So. 2d 1018 (Fla. 5th DCA 2003)
- Kent v. State, 842 So. 2d 234 (Fla. 5th DCA 2003)
- Ritchie v. State, 842 So. 2d 234 (Fla. 5th DCA 2003)