Herrera Gutierrez — Florida appellate court reversed judgments, sentences, and liens after the State confessed error

Case
Victor Esteban Herrera Gutierrez v. State of Florida
Court
Florida Fifth District Court of Appeal
Judge
LAMBERT (Rick Scott, 2014); Boatwright (Ron DeSantis, 2022); KILBANE (Ron DeSantis, 2022)
Date Decided
August 14, 2026
Docket No.
5D2026-0928; 5D2026-0930
Topics
Criminal Procedure; Subject Matter Jurisdiction; Charging Documents; Confession of Error
Source
Read the full opinion

Background

Victor Esteban Herrera Gutierrez appealed judgments and sentences entered by the County Court for Marion County in two cases.

He argued that the county court lacked subject matter jurisdiction because no valid charging documents had been filed. The State filed a confession of error.

The Court’s Holding

The Florida Fifth District Court of Appeal accepted the State’s confession of error. The brief per curiam opinion did not separately analyze or expressly adjudicate the factual premise of Herrera Gutierrez’s charging-document argument.

The court reversed the judgments, sentences, and liens and remanded the cases for further proceedings.

Key Takeaways

  • Herrera Gutierrez challenged the county court’s subject matter jurisdiction based on the alleged absence of valid charging documents.
  • The State confessed error, and the appellate court accepted that confession.
  • The court reversed the judgments, sentences, and liens and remanded for further proceedings.

Why It Matters

The decision shows that a jurisdictional challenge based on charging documents can require reversal when the State confesses error and the appellate court accepts that confession. Because the opinion provides no independent analysis of the charging documents or jurisdictional issue, its express holding is limited to the stated disposition.

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