STATE OF FLORIDA, APPELLANT,
v.
AMANDA MARIE DAHL, APPELLEE
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Florida appealed a trial court's order withholding adjudication of guilt for a defendant convicted of leaving the scene of a crash involving death, a first-degree felony. The appellate court reversed the withhold of adjudication and remanded for entry of an adjudication of guilt, holding that Florida law prohibits withholding adjudication for first-degree felonies and that the trial court lacked jurisdiction to modify its judgment after the appeal was filed.
The trial court erred in withholding adjudication of guilt because Florida law prohibits withholding adjudication for first-degree felonies. Additionally, the trial court lacked jurisdiction to enter the corrected sentencing order and amended judgment because the filing of the State's appeal divested the trial court of jurisdiction.
[1] A trial court errs by withholding adjudication of guilt for a first-degree felony offense when a statute prohibits such withholding.
[2] A trial court is divested of jurisdiction to amend a judgment or sentence once a notice of appeal has been filed by the State.
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“the trial court erred in this case because section 775.08435(l)(a), Florida Statutes (2015), prohibits a court from withholding adjudication of guilt for "[a]ny capital, life, or first degree felony offense."”
Establishes the statutory prohibition against withholding adjudication for first-degree felonies
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Join FLexlaw to unlock all legal intelligenceAmanda Marie Dahl entered a guilty plea to leaving the scene of a crash involving death, a first-degree felony. The trial court sentenced her to 364 d…
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Amanda Marie Dahl (“Appellee”) entered a guilty plea to one count of leaving the scene of a crash involving death, a first degree felony. She was sentenced to 364 days in jail and ten years’ probation with several special conditions. Over the State’s objection, the trial court entered an order withholding adjudication of guilt. The State appealed this order under Florida Rule of Appellate Procedure 9.140(c)(l)(L).
After the State’s notice of appeal was filed, the trial court recognized its mistake, entered an order that its previous withhold of adjudication was now “converted” to an adjudication of guilt, issued a new sentencing order, and amended the judgment to adjudicate Appellee guilty. Thereafter, the State filed its motion to quash the amended judgment and sentencing order, arguing that the trial court did not have jurisdiction to enter an amended judgment adjudicating Appellee guilty because the State already filed a notice of appeal and an appellate case number was assigned. The court denied that motion without a hearing. Our review is de novo. Cromartie v. State, 70 So.3d 559, 563 (Fla. 2011).
As Appellee concedes, the trial court erred in this case because section 775.08435(l)(a), Florida Statutes (2015), prohibits a court from withholding adjudication of guilt for “[a]ny capital, life, or first degree felony offense.” See also State v. Foster, 114 So.3d 422, 422 (Fla. 5th DCA 2013) (reversing trial court’s withhold of adjudication on a first degree felony, and remanding for an adjudication of guilt).
Further, the trial court lacked jurisdiction to enter its corrected sentencing order and amended judgment because the trial court was divested of jurisdiction when the State filed its appeal. See Gonzalez v. State, 384 So.2d 57, 58 (Fla. 4th DCA 1980) (filing notice of appeal vested exclusive jurisdiction in appellate court and trial court was prohibited from modifying sentence after appeal was filed).
Accordingly, we reverse the trial court’s withhold of adjudication and remand for entry of an adjudication of guilt.
Reversed and Remanded.
Conner and Forst, JJ., concur.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Cromartie v. State, 70 So. 3d 559 (Fla. 2011)
- Fuse v. State, 384 So. 2d 57 (Fla. 4th DCA 1980)
- State v. Foster, 114 So. 3d 422 (Fla. 5th DCA 2013)
- Troche-Vazquez v. State, 114 So. 3d 422 (Fla. 5th DCA 2013)