STATE OF FLORIDA, PETITIONER,
v.
LAMAR LYLES, RESPONDENT
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The Florida Supreme Court reviews whether a trial court's insufficient inquiry into the factual basis for a guilty plea to robbery violated procedural rules. The Court holds that while the plea should not be vacated outright, remand to the trial court is necessary to conduct a proper factual basis inquiry.
The Court holds that while the trial court's limited inquiry was inadequate, the plea should not be vacated. Instead, the case should be remanded to the trial court to conduct a proper searching inquiry into the factual basis, allow the defendant to present evidence, and determine whether manifest injustice occurred.
[1] A trial court must determine that there is a factual basis for a guilty plea.
[2] A trial court's failure to ascertain the factual basis for a guilty plea requires further inquiry, even if the plea is not vacated.
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Join FLexlaw to unlock all legal intelligence“When such circumstances are present, the trial judge should make a searching inquiry to determine whether the defendant understands that the plea waives any asserted defense.”
Establishes the standard for judicial inquiry required before accepting a guilty plea
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Join FLexlaw to unlock all legal intelligenceLyles, a 19-year-old defendant with family present, pleaded guilty to robbery. The trial court's plea inquiry was minimal, asking only whether Lyles u…
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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 299 So. 2d 146 (Fla.App. 1st 1974). The decision sought to be reviewed conflicts with Estes v. State, 294 So. 2d 122 (Fla.App. 1st 1974); Hall v. State, 303 So. 2d 417 (Fla.App. 2d 1974); and Williams v. State, 316 So. 2d 303 (Fla.App.2d 1974). We have jurisdiction under Article V, Section 3(b)(3), Florida Constitution.
At issue is the failure of the trial court to ascertain the particulars of the robbery to which the defendant admitted his guilt. It is alleged that this shortcoming violates Rule of Criminal Procedure 3.170(j) which requires the court to determine “that there is a factual basis for the plea.” The First District held in the instant case that the language of the aforementioned rule was mandatory and did not allow the appellate court an opportunity to determine whether the trial court’s lack of inquiry resulted in prejudicial error to the defendant. The District Court vacated the plea and remanded the cause to the trial court.
The principles of our decision in Williams v. State, 316 So. 2d 267 (Fla.1975), are applicable to this cause.
The record in the instant case reflects that the trial court made only limited inquiry of a 19-year-old defendant. Present with the defendant before the court were four members of his family. After the defendant was advised of the offense and penalty, the following inquiry and response appear in the record:
“THE COURT: By pleading guilty you have admitted that the State can prove each essential allegation of that crime. Do you understand that ?
“MR. LYLES: (Nods head.)”
Also during this inquiry, the trial court asked this question:
“THE COURT: . . . Have you had an opportunity to talk to Mr. Cosgrove, your attorney, about . . . any possible defenses you may have for this charge and the consequences of your entering a guilty plea here today ? ”
to which the defendant-Lyles answered, “Yes, sir.”
At the sentencing proceedings approximately three weeks later the following colloquy took place:
“THE COURT: The victim in this case, which you decided that you would beat up seriously—
“MR. LYLES: I assaulted the man because he was trying to take my money. He was cheating me.
“THE COURT: So you caved in his face, which necessitated having plastic surgery. You broke him up inside, which necessitated to have his stomach cut up and the man has permanent injuries, and that’s the excuse you have? Did you ever think of calling the police?
“MR. LYLES: No, sir. At the time, I was under1 the influence of alcohol and marijuana.
“THE COURT: Well, I think I’m going to put you away where you’re not going to get either one. Anything else ?
“MR. LYLES: No, sir.”
No further inquiry was made concerning the inference of a possible defense to the charge.
The factual circumstances of this case are very similar to those in McCarthy v. United States, 394 U.S. 459, 89 S.Ct. 1166, 22 L.Ed.2d 418 (1969). When such circumstances are present, the trial judge should make a searching inquiry to determine whether the defendant understands that the plea waives any asserted defense. While we do not agree with the District Court that the plea should be vacated, the statements made by the defendant, coupled with the trial judge’s failure to ascertain the factual basis for the plea, is sufficient to require further inquiry by the trial court. We are not vacating the plea at this time as was done in McCarthy v. United States, supra.
We direct the District Court to remand this cause to the trial court for the following purposes: (a) to make inquiry of the defendant and his counsel concerning their discussions relative to the defenses to the charge; (b) to receive evidence of a factual basis for the plea; and (c) to allow the defendant an opportunity to present evidence on his own behalf to show how, if at all, manifest injustice occurred.
The decision of the District Court is quashed, and the cause is remanded with directions to remand this cause to the trial court for proceedings consistent with this opinion.
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 (27 total)
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State v. Bunyan L. Kendrick, Jr., 336 So. 2d 353 (Fla. 1976)…here a defendant raises the possibility of a defense to his guilty plea, the potential prejudice is apparent. In such circumstances, a trial judge should make extensive inquiry into factual basis before accepting the guilty plea. See State v. Lyles, 316 So. 2d 277 (Fla.1975)., Correspondingly, the showing in the record of the source of the factual information supporting the plea (required by Williams v. State, supra at 273) should be made with greater specificity than was done in the instant case. The court…
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Walden v. State, 319 So. 2d 51 (Fla. 1st DCA 1975)…t are not prejudicial or harmful do not require reversal. * * * ” (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 d…
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Williams v. State, 534 So. 2d 929 (Fla. 4th DCA 1988)…fendant raises the possibility of a defense in the course of his response, the potential prejudice is considered apparent and a further inquiry by the trial court is necessary. See State v. [*931] Kendrick, 336 So. 2d 353 (Fla.1976); State v. Lyles, 316 So. 2d 277 (Fla.1975). See also Monroe v. State, 318 So. 2d 571 (Fla. 4th DCA 1975); Miles v. State, 338 So. 2d 547 (Fla. 3d DCA 1976). We conclude that the court’s inquiry here was insufficient, and that appellant has met his burden of demonstrating prejudic…
Previewing 3 of 27 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- McCARTHY v. United States, 394 U.S. 459 (U.S. 1969)
- 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)
- Jensen v. Kaplan, 303 So. 2d 417 (Fla. 3d DCA 1974)
- Williams v. State, 316 So. 2d 303 (Fla. 2d DCA 1974)