MARIO A. MANBORDE
v.
THE STATE OF FLORIDA
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A defendant is bound by statements made under oath during a plea colloquy and cannot invalidate a negotiated plea by subsequently claiming perjury regarding those sworn statements.
[1] A defendant is bound by the statements made under oath during a plea colloquy.
[2] A defendant seeking to invalidate a plea based on claims of perjury during the plea colloquy is bound by their sworn answers.
Previewing 2 of 3 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“a plea conference is not a meaningless charade to be manipulated willy-nilly after the fact; it is a formal ceremony, under oath, memorializing a crossroads in a case”
The court quoted this language from Scheele v. State to emphasize the binding nature of plea colloquies.
Manborde appealed a trial court's denial of his motion for postconviction relief, which sought to vacate a judgment and sentence entered pursuant to a…
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PER CURIAM.
Affirmed. See Rodriguez v. State, 223 So. 3d 1095, 1097 (Fla. 3d DCA 2017) (affirming trial court’s denial of a motion for postconviction relief seeking to vacate a judgment and sentence entered pursuant to a negotiated plea, observing: “The record, which includes the plea colloquy, clearly refutes these claims, and under Florida law, a defendant is bound by the statements he makes under oath during a plea colloquy. See Henry v. State, 920 So. 2d 1245, 1246 (Fla. 5th DCA 2006) (“This motion presents the all-too-common occurrence where defendants, in an attempt to invalidate their pleas, contend they committed perjury when they sought to have their pleas accepted. Defendants are bound by the statements made by them under oath ....”); Iacono v. State, 930 So. 2d 829, 831–32 (Fla. 4th DCA 2006) (holding that defendants “are bound by their sworn answers” during a plea colloquy). As the Fourth District Court of Appeal stated in Scheele v. State, 953 So. 2d 782, 785 (Fla. 4th DCA 2007), “[a] plea conference is not a meaningless charade to be manipulated willy-nilly after the fact; it is a formal ceremony, under oath, memorializing a crossroads in a case.”))
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Citator
Cited By
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Ira Toomer v. State (Fla. 3d DCA 2025)
Authorities Cited
- Iacono v. State, 930 So. 2d 829 (Fla. 4th DCA 2006)
- Huff v. Unemployment Appeals Comm'n, 953 So. 2d 782 (Fla. 4th DCA 2007)
- Henry v. State, 920 So. 2d 1245 (Fla. 5th DCA 2006)
- Wilber Rodriguez v. State, 223 So. 3d 1095 (Fla. 3d DCA 2017)