Background
T.A.S., a juvenile, entered a negotiated plea agreement in several cases. 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 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 held that the classifications in the written disposition orders were clerical errors. The record showed that the trial court accepted the plea agreement and did not make a judicial decision to impose classifications different from those in the agreement.
The appellate court reversed and remanded for entry of corrected disposition orders that conform to the plea agreement. It relied on the distinction between a scrivener’s error—a written clerical mistake conflicting with the oral pronouncement or record—and an error resulting from a judicial determination.
Key Takeaways
- A juvenile disposition order may be corrected when a clerical mistake causes it to conflict with an accepted plea agreement.
- A scrivener’s error is distinct from an error arising from the trial court’s judicial decision.
- The proper remedy was reversal and remand for corrected disposition orders matching the plea agreement.
Why It Matters
The decision confirms that written juvenile disposition orders must accurately reflect the terms of a plea agreement accepted by the trial court. When the record shows no intent to depart from those terms, inconsistent offense classifications may be treated as clerical errors rather than substantive sentencing decisions.