Background
T.A.S., a juvenile, entered into a negotiated plea agreement with the State. The trial court accepted the plea, signed the written agreement, and did not indicate that it intended to depart from the agreement’s terms.
The resulting disposition orders, however, incorrectly classified several offenses. T.A.S. appealed those orders, and the State conceded that the classifications should be corrected to match the plea agreement.
The Court’s Holding
The First District Court of Appeal held that the incorrect offense classifications were scrivener’s errors. The written orders conflicted with the record and the accepted plea agreement, rather than reflecting a judicial decision to impose different classifications.
The court reversed the disposition orders and remanded for entry of corrected orders conforming to the plea agreement.
Key Takeaways
- A disposition order must accurately reflect the terms of a plea agreement accepted by the trial court.
- A clerical error in a written order may be corrected as a scrivener’s error when it does not result from a judicial determination.
- The appellate court reversed and remanded solely for corrected disposition orders.
Why It Matters
The decision confirms that courts may correct written juvenile disposition orders when clerical mistakes cause them to depart from an accepted plea agreement. It also distinguishes a correctable scrivener’s error from a substantive judicial sentencing decision.