Background
T.A.S., a juvenile, entered into a negotiated plea agreement with the State. 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 in a manner inconsistent with the plea agreement. The State conceded that the discrepancies were scrivener’s errors requiring correction.
The Court’s Holding
The First District Court of Appeal held that the disposition orders should be corrected to conform to the negotiated plea agreement. The record showed that the trial court accepted and signed the agreement and did not express an intent to impose terms different from those contained in it.
The court treated the incorrect offense classifications as clerical, or scrivener’s, errors rather than errors arising from a judicial determination. It reversed and remanded for entry of corrected disposition orders.
Key Takeaways
- A written disposition order may be corrected when a clerical error causes it to conflict with the plea agreement accepted by the trial court.
- The trial court’s acceptance and signature supported the conclusion that it intended to follow the negotiated agreement.
- The remedy was reversal and remand for corrected orders, consistent with the State’s concession.
Why It Matters
The decision underscores that juvenile disposition orders must accurately reflect the terms of an accepted negotiated plea. When the record establishes that a discrepancy is clerical rather than the product of judicial decision-making, correction of the written orders is the appropriate remedy.