MICHAEL WATERS
v.
STATE OF FLORIDA

Fla. 2d DCA | 2020-09-04
No. 19-4431
PARIS
Florida District Court of Appeal, Second District (2020)

AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.


Holding

When a conflict exists between the trial court's oral pronouncement of sentence and the written sentencing documents, the oral pronouncement controls and the documents must be corrected accordingly.


Headnotes

[1] When a conflict exists between a trial court's oral pronouncement of sentence and the written sentencing documents, the oral pronouncement controls.

[2] A scrivener's error in sentencing documents may be corrected on remand to conform to the trial court's oral pronouncement.

Previewing 2 of 2 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

Key Quotes

“When a conflict exists between the trial court's oral pronouncement of sentence and the written sentencing documents, the oral pronouncement controls.”

Court citing Bryant v. State to establish the controlling rule for resolving conflicts between oral and written sentencing documents.

Facts & Procedural History

Michael Waters appealed the revocation of his probation and the sentence imposed upon revocation. The trial court orally pronounced a five-year term o…

The full statement of facts, procedural history, and disposition for this case are member content.

Join FLexlaw to unlock all legal intelligence

© FLexlaw, Inc. — AI-generated enrichments are proprietary. All rights reserved.


Opinion of the Court

Appeal from the Circuit Court for Polk County; William D. Sites, Judge.

Howard L. Dimmig, II, Public Defender, and Pamela H. Izakowitz, Assistant Public Defender, Bartow, for Appellant.

Ashley Moody, Attorney General, Tallahassee, and Johnny T. Salgado, Assistant Attorney General, Tampa, for Appellee.

ROTHSTEIN-YOUAKIM, Judge.

Michael Waters appeals the order revoking his probation and the sentence imposed upon revocation. Just as we did in case number 2D19-33, we affirm in all respects but remand for correction of a scrivener's error pertaining to count two in the underlying sentencing documents.

Despite the trial court's oral pronouncement that Waters' sentence on count two was a five-year term of probation consecutive to the ten-year prison term on count three, the written sentencing documents incorrectly reflect a split sentence on count two of five years' imprisonment followed by five years' probation. Consequently, we remand with instructions for correction of the written sentencing documents to comport with the trial court's oral pronouncement. See Bryant v. State, 45 Fla. L.

Weekly D520b, D520b (Fla. 2d DCA Mar. 6, 2020) ("When a conflict exists between the trial court's oral pronouncement of sentence and the written sentencing documents, the oral pronouncement controls." (citing Williams v. State, 957 So. 2d 600, 603 (Fla. 2007))).

Affirmed; remanded to correct scrivener's error. NORTHCUTT and SILBERMAN, JJ., Concur.


Cases With Similar Vibessemantic neighbors from the corpus


Citator

Authorities Cited

Full citator, related cases, and AI research tools

Open in FLexlaw