T.A.S., A CHILD
v.
STATE OF FLORIDA

Fla. 1st DCA | 2026-08-26
No. 2025-2387
Bullard, J., Kelsey, J., Nordby, J., Neff, J.
2026 FL 10911 Florida District Court of Appeal, First District (2026)

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Holding

A trial court's disposition orders that misclassify offenses in violation of a negotiated plea agreement constitute scrivener's errors remediable on appeal.


Headnotes

[1] A scrivener's error in a disposition order that conflicts with the terms of a negotiated plea agreement and the oral pronouncement may be corrected on appeal without requ…

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Key Quotes

“a scrivener's error refers to a written clerical error not due to 'judicial determination or error' that conflicts 'with the oral pronouncement of sentence or the record'”

Court's citation to Ashley v. State defining scrivener's error in the context of sentencing and disposition orders

Facts & Procedural History

T.A.S., a juvenile, entered into a negotiated plea agreement with the State. The trial court accepted the plea and signed the written plea agreement b…

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Opinion of the Court

FIRST DISTRICT COURT OF APPEAL

STATE OF FLORIDA

T.A.S., a Child, Appellant,

v.

STATE OF FLORIDA, Appellee.

Nos. 1D2025-2383 1D2025-2384 1D2025-2385 1D2025-2387 1D2025-2388 1D2025-2389

On appeal from the Circuit Court for Alachua County. Susanne Wilson Bullard, Judge.

August 26, 2026

PER CURIAM.

T.A.S., a juvenile, appeals from the trial court's disposition orders, contending that the orders incorrectly classified several offenses contrary to a negotiated plea agreement. The record establishes that the trial court accepted T.A.S.'s plea, signed the written plea agreement, and gave no indication that it intended to depart from the terms of the agreement. Accordingly, we remand for correction of the scrivener's errors, as conceded by the State, to comport with the terms of the plea agreement. See Ashley v. State,

850 So. 2d 1265, 1268 n.3 (Fla. 2003) (outlining that a scrivener's error refers to a written clerical error not due to “judicial determination or error" that conflicts "with the oral pronouncement of sentence or the record").

REVERSED and REMANDED for entry of corrected disposition orders.

KELSEY, NORDBY, and NEFF, JJ., concur.


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