CONNIE LEON
v.
STATE OF FLORIDA

Fla. 4th DCA | 2026-05-20
No. 2025-0456
Buchanan, J., Gross, J., May, J., Klingensmith, J.
2026 FL 5995 Florida District Court of Appeal, Fourth District (2026) Positive Treatment
Cited by 3 cases

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Holding

Scrivener's errors in sentencing scoresheets, including incorrect offense listings and case information, must be corrected on remand.


Headnotes

[1] Scrivener's errors in sentencing scoresheets, such as incorrect offense listings and case information, are subject to correction under Florida Rule of Criminal Procedure…

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Key Quotes

“Florida courts have consistently permitted the correction of scrivener's errors.”

Court's statement of applicable law regarding correction of sentencing scoresheet errors

Facts & Procedural History

Connie Leon appealed the trial court's denial of her motions to correct sentencing errors in two criminal cases. The 2022 case scoresheet erroneously …

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Opinion of the Court

DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA

FOURTH DISTRICT

CONNIE LEON, Appellant,

V.

STATE OF FLORIDA, Appellee.

Nos. 4D2025-0456 and 4D2025-0580

[May 20, 2026]

Consolidated appeals from the Circuit Court for the Nineteenth Judicial Circuit, Okeechobee County; Laurie E. Buchanan, Judge; L.T. Case Nos. 472022CF000459CFAXMX and 472024CF000359CFAXMX.

Daniel Eisinger, Public Defender, and Ethan Goldberg, Assistant Public Defender, West Palm Beach, for appellant.

James Uthmeier, Attorney General, Tallahassee, and Nathanial LeBlanc, Assistant Attorney General, West Palm Beach, for appellee.

ON CONFESSION OF ERROR

PER CURIAM.

Appellant Connie Leon appeals the trial court's denial of her Florida Rule of Criminal Procedure 3.800(b)(2) motions to correct sentencing errors in two cases, arguing that the errors in both scoresheets require resentencing.1 We reverse only for the ministerial corrections of the scrivener's errors in the scoresheets and affirm all other issues raised without comment.

In the 2022 case, the scoresheet erroneously listed the primary offense as possession of methamphetamine. In the 2024 case, the scoresheet listed the incorrect case number, offense date and primary offense. “Florida courts have consistently permitted the correction of scrivener's errors.” Allen v. State, 421 So. 3d 708, 710 (Fla. 4th DCA 2025). As the

State correctly concedes error on these issues, we reverse and remand for the correction of these scrivener's errors.

Affirmed in part, reversed in part and remanded.

GROSS, MAY and KLINGENSMITH, JJ., concur.

* * *

Footnotes
1 Case 2022000459CF (“2022 case”) and case 2024000359CF (“2024 case”).

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