WILLIAM ESTES, PETITIONER,
v.
STATE OF FLORIDA, RESPONDENT
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The Florida Supreme Court addressed whether trial courts must make a full factual basis inquiry for guilty pleas entered through plea bargaining under Criminal Procedure Rule 3.170(j). The Court held that the factual basis requirement applies even to negotiated pleas, but pleas subject to attack on a manifest injustice standard when the inquiry is omitted.
The factual basis requirement of Rule 3.170(j) applies to negotiated guilty pleas and cannot be eliminated merely because the plea resulted from plea bargaining. When the rule has not been complied with, the plea is subject to attack on a manifest injustice standard.
[1] A trial court must determine a factual basis for a guilty plea, as required by Rule of Criminal Procedure 3.170(j).
[2] A negotiated plea is a factor to be considered in determining the validity of a guilty plea, but it is not controlling.
Previewing 2 of 4 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“The fact that the plea is negotiated does not eliminate the "factual basis" requirement from the rule. When the rule has not been complied with, the plea is subject to attack on the manifest injustice standard set forth in Williams v. State, supra.”
Establishes the core holding that the factual basis requirement applies to plea-bargained guilty pleas and the standard for challenging such pleas.
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Join FLexlaw to unlock all legal intelligenceWilliam Estes was charged with possession of hallucinogenic drugs (count one) and sale of hallucinogenic drugs. The State agreed to abandon the first …
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OVERTON, Justice.
This cause is before us on petition for writ of certiorari to review the decision of the First District Court of Appeal reported at 294 So. 2d 122 (Fla.App. 1st 1974). The decision sought to be reviewed conflicts with another decision of the same court, Lyles v. State, 299 So. 2d 146 (Fla.App. 1st 1974). At issue in this cause is the appropriateness of the guilty plea procedure and the apparent failure of the trial judge to make a full inquiry into the factual basis for the plea, pursuant to Rule of Criminal Procedure 3.170(j). The First District has itself recognized the conflict of its own decisions. We have jurisdiction under Article V, Section 3(b)(3), Florida Constitution.
The record of the plea clearly reflects that the defendant voluntarily entered the plea with knowledge of the consequences. Concerning the particular offense with which the defendant was charged, the following inquiry and response appear:
“THE COURT: By pleading guilty you have admitted that you have committed the crime, and the State has abandoned the first count, which was possession of hallucinogenic drugs, but you have further admitted that the State can prove the sale of hallucinogenic drugs, do you understand that?
“MR. ESTES: Yes, sir.”
The record further reflects that the court had agreed to impose a two year sentence for this offense, for which the maximum penalty was five years. The defendant understood and approved this agreement. Williams v. State, 316 So. 2d 267 (Fla.1975), is controlling. There has been no showing by the defendant of prejudice or manifest injustice. We agree with the District Court of Appeal that the defendant has failed to demonstrate in this record how he has been prejudiced by the particular guilty plea procedure used in this cause. We do not agree, however, with the holding of the District Court that “the factual basis clause in that rule [Rule 3.170(j)] is inapplicable in cases where the guilty plea is the result of plea bargaining.” The fact that the plea is negotiated does not eliminate the “factual basis” requirement from the rule. When the rule has not been complied with, the plea is subject to attack on the manifest injustice standard set forth in Williams v. State, supra.
The result reached by the District Court is affirmed.
It is so ordered.
ADKINS, C. J., ROBERTS and ENGLAND, JJ., and CARLISLE, Circuit Judge, concur.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By (16 total)
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Lavigne v. State, 349 So. 2d 178 (Fla. 1st DCA 1977)…on Standard clearly puts the burden on the defendant to ‘prove’ a ‘manifest injustice’ has occurred. In other words, clear prejudice must be shown. * * * ” (316 So. 2d at page 274; emphasis added) On the same date the same court, in Estes v. State, 316 So. 2d 276 (Fla.1975), affirming the result reached by this Court which affirmed appellant’s conviction, said: “Williams v. State, 316 So. 2d 267 (Fla. 1975), is controlling. There has been no showing by the defendant of prejudice or manifest injustice. We ag…
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State v. Bunyan L. Kendrick, Jr., 336 So. 2d 353 (Fla. 1976)…t with Estes v. State, supra. The defendant in Estes did not “say or contend that indeed there was no factual basis for his guilty plea.” 294 So. 2d at 123. Further, the conflict within the Estes opinion was resolved by this Court in Estes v. State, 316 So. 2d 276 (Fla.1975), when we recognized that “[t]he fact that the plea is negotiated does not eliminate the ‘factual basis’ requirement . . . 316 So. 2d at 277. Nor is there conflict with Mower v. State, supra. In Mower, the District Court noted that the tr…
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Walden v. State, 319 So. 2d 51 (Fla. 1st DCA 1975)…al. * * * ” (246 So. 2d at page 774) (To like effect are Johnson v. State, Sup.Ct. Fla.1974, 308 So. 2d 38; Williams v. State, Sup.Ct. Fla.1975, 316 So. 2d 267; State v. Lyles, Sup.Ct. Fla.1975, 316 So. 2d 277; and Estes v. State, Sup.Ct. Fla.1975, 316 So. 2d 276). No prejudice nor harm has been demonstrated. Further, as already above observed, the evidence in the case sub judice was so clear and convincing as to leave no reasonable doubt but that the defendant was guilty of the crimes for which he was con…
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Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Williams v. State, 316 So. 2d 267 (Fla. 1975)
- Estes v. State, 294 So. 2d 122 (Fla. 1st DCA 1974)
- Lyles v. State, 299 So. 2d 146 (Fla. 1st DCA 1974)