HUBERT ROBERT CRUSOE, APPELLANT,
v.
THE STATE OF FLORIDA, APPELLEE
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.
Crusoe appealed the denial of his post-conviction motion to vacate a guilty plea to four counts of uttering and passing forged bank checks, claiming involuntary drunkenness negated his criminal intent. The court affirmed the denial, holding that a guilty plea in open court with counsel waives all factual issues of guilt and that drunkenness, whether voluntary or involuntary, does not legally excuse criminal conduct involving acts requiring knowledge of one's actions.
The court held that a guilty plea entered in open court with counsel present waives all questions of guilt or innocence from a factual standpoint, and that a defendant's post-plea claim of ignorance regarding a potential legal defense cannot constitute grounds for relief. Furthermore, involuntary drunkenness, by itself, does not necessarily immunize a person from criminal liability for felonious conduct involving acts that by their nature presuppose knowledge of what one is doing.
[1] A guilty plea entered in open court with counsel present waives factual questions regarding guilt or innocence.
[2] A defendant's ignorance of a potential defense at the time of pleading guilty does not render the plea involuntary if the defense is not legally valid.
Previewing 2 of 5 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“his pleas of guilty put at rest all questions of his guilt or innocence from a factual standpoint”
Establishes that guilty pleas waive factual issues of guilt or innocence
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceCrusoe was charged by separate informations with uttering and passing four forged bank checks. On June 5, 1964, represented by court-appointed counsel…
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.
Explore caselaw by topic → Browse Crpr 1.850 cases and more on FLexlaw
Appellant Hubert Robert Crusoe appeals to this Court from an order denying his motion to vacate filed under CrPR 1.850, 33 F.S.A.
By separate informations, Crusoe was charged with uttering and passing four forged bank checks. Attended by Court-appointed counsel, Crusoe appeared in open Court on June 5, 1964 and withdrew pleas of not guilty previously entered to the infor-mations and in lieu thereof pleaded guilty to all four charges, receiving a concurrent sentence to the State Prison.
On April 9, 1970, he filed a post-conviction petition in the trial Court, seeking to have such sentences declared void. As frequently occurs, the petition is rambling and in large part incoherent, but as we construe it his contention is that at the time of commission of the acts constituting the basis of the prosecution, namely, the passing of the forged checks, he was not legally competent to commit the offenses due to “involuntary drunkenness” (whatever that is); that his condition rendered him unable to entertain the requisite intent to defraud required by law to make out the offenses charged; and that when he appeared in Court to change his pleas to guilty “he did not know that under Florida law he was not responsible for these wrongful acts”.
On April 10, 1970, the trial Judge entered order denying the petition, reciting that on five previous occasions subsequent to entry of sentence Crusoe had been before that Court on various motions, either to dismiss the charges, or to mitigate the sentences, or to vacate the sentences, all of which had been denied, and that at least one of the orders of denial has been appealed and affirmed by this Court. It does not distinctly appear from the trial Judge’s order of April 10, 1970, that any of Crusoe’s previous motions contained the identical ground set forth in his current motion, so that the instant order cannot be summarily upheld because of previous motions filed and adversely ruled upon.
However, the order appealed from must be affirmed because the motion on its face shows that Crusoe pleaded guilty in open Court in presence of his counsel to four separate felonies with full knowledge of his mental and/or physical condition at the time of commission of the acts for which he was before the Court. Furthermore, his pleas of guilty put at rest all questions of his guilt or innocence from a factual standpoint. And the fact, as he so contends, that he “did not know”, at the time he pleaded guilty, that he had a “good defense” cannot avail him.
In the first place, it was not a good defense, because it does not follow, as a matter of law, that mere drunkenness, whether voluntary or involuntary, neces*149sarily immunizes a person from the consequences of his felonious conduct involving acts which, by their very nature, presuppose a binding knowledge of what he is doing. Also, he does not in any way impugn the competence of his Court counsel and it must therefore be assumed that Crusoe was sufficiently advised of all legal attributes of the charges against him and of his legal amenability to such charges.
The order denying relief must therefore be affirmed.
Affirmed.
LILES, A. C. J., and McNULTY, J., concur.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By
-
Linehan v. State, 476 So. 2d 1262 (Fla. 1985)…); Folks v. State, 85 Fla. 288, 95 So. 619 (1923) (manslaughter); Link v. State, 429 So. 2d 836 (Fla. 3d DCA 1983) (possession of methaqualudes); Williams v. State, 250 So. 2d 11 (Fla. 3d DCA 1971) (violence while resisting arrest); Crusoe v. State, 239 So. 2d 147 (Fla. 2d DCA 1970) (passing forged bank checks). As noted above, voluntary intoxication has been recognized in this state for more than ninety years as a valid defense to specific intent crimes. See Garner. We emphasize that voluntary intoxication…
-
Kelley v. State, 720 So. 2d 272 (Fla. 2d DCA 1998)…was sufficient evidence that the stolen vehicle or major component parts thereof for which restitution was properly ordered were present at appellant’s place of business. By pleading guilty, he waived any issue as to his guilt. See Crusoe v. State, 239 So. 2d 147 (Fla. 2d DCA 1970). It is not necessary that the State offer evidence of appellant’s actual involvement in the theft of the vehicles for which restitution is ordered. See § 812.16(3), Fla. Stat. (1995). [*273] Appellant next challenges the specific…