Background
T.A.S., a juvenile, entered a negotiated plea agreement with the State. The Circuit Court for Alachua County accepted the plea and signed the written agreement without indicating that it intended to depart from the agreement’s terms.
T.A.S. appealed the resulting disposition orders, arguing that they incorrectly classified several offenses contrary to the plea agreement. The State conceded that the discrepancies were scrivener’s errors requiring correction.
The Court’s Holding
The Florida First District Court of Appeal held that the disposition orders contained written clerical errors that conflicted with the record and the accepted plea agreement. Because the errors did not result from a judicial determination, they qualified as scrivener’s errors.
The court reversed and remanded for entry of corrected disposition orders that conform to the plea agreement.
Key Takeaways
- A written disposition order must accurately reflect the terms of a plea agreement accepted by the trial court.
- A clerical mistake that conflicts with the record, rather than an error arising from judicial decision-making, may be corrected as a scrivener’s error.
- The appellate court reversed and remanded solely for entry of corrected disposition orders.
Why It Matters
The decision confirms that juvenile disposition orders must faithfully record the terms under which a plea was accepted. When the record shows that an inconsistency is clerical rather than judicial, correction of the written orders is the appropriate remedy.