Background
T.A.S., a juvenile, entered a negotiated plea agreement in proceedings before the Circuit Court for Alachua County. The trial court 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 and therefore did not conform to the negotiated 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 reversed and remanded for entry of corrected disposition orders. It concluded that the record established the trial court’s acceptance of the plea agreement and contained no indication of an intended departure from its terms.
The court treated the incorrect offense classifications as scrivener’s errors—written clerical mistakes, rather than errors arising from a judicial determination—and directed the trial court to correct the orders so they comport with the plea agreement.
Key Takeaways
- A written juvenile disposition order should accurately reflect the terms of a negotiated plea agreement accepted by the trial court.
- A conflict caused by a clerical mistake in a written order may be corrected as a scrivener’s error when it does not reflect a judicial determination.
- The appellate court reversed and remanded for corrected orders rather than directing reconsideration of the negotiated plea.
Why It Matters
The decision underscores the importance of comparing written disposition orders with the plea agreement and the full record. When an accepted agreement is inaccurately reduced to writing, an appellate court may require correction of the clerical discrepancy so the operative orders reflect the adjudicated terms.