JAHLEEL TAFARI EATON
v.
STATE OF FLORIDA

Fla. 4th DCA | 2023-05-31
No. 22-2796
Florida District Court of Appeal, Fourth District (2023)

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Holding

A conviction following a non-jury trial must be reversed when the record lacks both a written waiver of jury trial and a trial judge's colloquy establishing that the waiver was made voluntarily, knowingly, and intelligently.


Headnotes

[1] A trial court's judgment following a non-jury trial must be reversed where the record contains neither a written waiver of jury trial complying with Florida Rule of Crimi…

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Key Quotes

“the record reflects neither a written waiver of jury trial, see Fla. R. Crim. P. 3.260, nor the trial judge's colloquy with Eaton demonstrating that his waiver of a jury trial was voluntarily, knowingly, and intelligently made”

Court's explanation of the defect requiring reversal

Facts & Procedural History

Jahleel Eaton was convicted of petit theft after a non-jury trial in county court. The appellate record contained no written waiver of jury trial and …

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Opinion of the Court

PER CURIAM.

Jahleel Eaton appeals his conviction of petit theft after a non-jury trial. As the state concedes, the record reflects neither a written waiver of jury trial, see Fla. R. Crim. P. 3.260, nor the trial judge’s colloquy with Eaton demonstrating that his waiver of a jury trial was voluntarily, knowingly, and intelligently made. See Sinkfield v. State, 681 So. 2d 838 (Fla. 4th DCA 1996); Walker v. State, 149 So. 3d 170 (Fla. 4th DCA 2014). We therefore reverse the conviction and sentence and remand to the county court for a new trial.

Reversed and remanded.

KLINGENSMITH, C.J., WARNER and GROSS, JJ., concur.

* * * Not final until disposition of timely filed motion for rehearing.

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