Background
T.A.S., a juvenile, appealed disposition orders entered by the Circuit Court for Alachua County. T.A.S. argued that the written orders incorrectly classified several offenses contrary to the terms of a negotiated plea agreement.
The record showed that the trial court accepted the plea and signed the written agreement without indicating that it intended to depart from the agreement’s terms. The State conceded that the classifications resulted from scrivener’s errors.
The Court’s Holding
The Florida First District Court of Appeal held that the disposition orders should be corrected to conform to the negotiated plea agreement. It explained that a scrivener’s error is a clerical mistake in a written order, rather than an error arising from a judicial determination, that conflicts with the oral pronouncement or the record.
The court reversed and remanded for entry of corrected disposition orders reflecting the plea agreement.
Key Takeaways
- A juvenile disposition order must accurately reflect the terms of a plea agreement accepted by the trial court.
- An incorrect offense classification may be corrected as a scrivener’s error when the mistake is clerical and conflicts with the record.
- The proper remedy here was reversal and remand for corrected disposition orders.
Why It Matters
The decision underscores the importance of checking written disposition orders against accepted plea terms. Clerical classifications can have legal consequences even when the judge did not intend to depart from the agreement.
When the record establishes the agreed disposition and the written orders do not conform, an appellate court may remand for correction without treating the discrepancy as a new judicial sentencing decision.