CYNTHIA SCHWARTZ, APPELLANT,
v.
STATE OF FLORIDA, MICHAEL J. SATZ, STATE ATTORNEY OF THE SEVENTEENTH JUDICIAL CIRCUIT, APPELLEE
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Cynthia Schwartz, charged with trafficking in cocaine, agreed to submit to a polygraph test as part of a substantial assistance plea arrangement. After failing the test, she filed a civil suit seeking to enjoin the state from using the results against her in the criminal action. The appellate court affirmed the trial court's dismissal, holding that a civil court cannot preempt criminal court proceedings through injunction.
A civil court sitting as a court of equity cannot preempt or control proceedings in a criminal court by issuing an injunction. The appropriate forum for Schwartz's arguments about the enforceability of the agreement is the criminal court itself, where the criminal judge must decide whether to invalidate the agreement.
[1] A civil court of equity cannot preempt the rulings of a criminal court or control its proceedings by issuing an injunction.
[2] A defendant may waive the constitutional privilege against self-incrimination as it pertains to the results of a polygraph test taken as part of a substantial assistance…
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Join FLexlaw to unlock all legal intelligence“Any attempt by the trial court, sitting as a court of equity, to preempt the criminal court's rulings or to otherwise control the proceedings in a criminal court by the issuance of an injunction would have been inappropriate.”
Establishes the fundamental principle that civil courts cannot use injunctions to interfere with criminal proceedings
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Join FLexlaw to unlock all legal intelligenceSchwartz was charged with trafficking in cocaine and entered into a Polygraph Agreement and Stipulation with the state as part of a substantial assist…
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SHAHOOD, J.
Appellant, Cynthia Schwartz, was charged criminally with trafficking in cocaine. As part of a substantial assistance plan, appellant entered into a Polygraph Agreement and Stipulation with the state, wherein she agreed to submit to a polygraph test. She also agreed that the test and anything pertaining to the test “shall be received in evidence either on behalf of the State of Florida or on [her] behalf in the [criminal action against her] or any retrial of same.” She waived her constitutional privilege against self-incrimination as it pertained to the results of the test and stipulated that “the focus of the examination in this case is whether or not” she was truthful in her sworn statement to the assistant state attorney concerning the cocaine.
Appellant submitted to the test and did not pass. In anticipation of the results being used against her, she thereafter filed a civil suit against the state asserting that the agreement was unenforceable and sought to permanently enjoin the state from using the test results against her in the criminal action. She also filed a Motion for Entry of Temporary Injunction, which the trial court dismissed.
Any attempt by the trial court, sitting as a court of equity, to preempt the criminal court’s rulings or to otherwise control the proceedings in a criminal court by the issuance of an injunction would have been inappropriate'. It is for the judge in the criminal court to consider appellant’s arguments at the appropriate time and decide whether to invalidate the agreement. See generally Metellus v. State, 817 So. 2d 1009, 1014 (Fla. 5th DCA 2002) (holding that a defendant will not be relieved of an obligation that was included as a specific component of a plea agreement that was bargained for and voluntarily entered into by defendant); see also Garcia v. State, 722 So. 2d 905 (Fla. 3d DCA 1998) (holding that a party may waive any right to which he is entitled and agreements containing such waivers will not be invalidated if the obligation was a specific component of a plea agreement that was bargained for and voluntarily entered into by the defendant).
Affirmed.
POLEN and KLEIN, JJ., concur.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Garcia v. State, 722 So. 2d 905 (Fla. 3d DCA 1998)
- Wilfrid Metellus v. State, 817 So. 2d 1009 (Fla. 5th DCA 2002)