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defendantjurisdictionstatuteappealtrialpleaguilty plea

defendantstatuteappealpleafelonycase lawappellantguilty plea

Related Cases

Robinson v. State, 373 So.2d 898

Facts

Tommy Lee Robinson was charged with aggravated battery and, after plea negotiations, pleaded guilty to aggravated assault. The trial court ensured that Robinson's plea was made voluntarily and intelligently, and he was sentenced to five years imprisonment. Following sentencing, Robinson filed a notice of appeal, which the state moved to dismiss, arguing it was frivolous and violated Florida Statutes.

The relevant facts are as follows. Appellant, Tommy Lee Robinson, was charged by an information with aggravated battery, a second-degree felony punishable by a maximum sentence of fifteen years imprisonment.

Issue

Whether the statute precluding direct appeals from guilty pleas is constitutional and whether the defendant has a right to appeal his guilty plea.

The issue presented to this Court by the appellant concerns the validity of the subject statute as it affects appellant's right to an appeal of his guilty plea.

Rule

The statute prohibits direct appeals from guilty pleas, allowing only for collateral attacks on the conviction. Appeals from guilty pleas are limited to issues that arise contemporaneously with the plea, such as subject matter jurisdiction and the voluntary nature of the plea.

A defendant who pleads guilty or nolo contendere with no express reservation of the right to appeal shall have no right to a direct appeal. Such a defendant shall obtain review by means of collateral attack.

Analysis

The court analyzed the statute's provisions and determined that it is constitutional as applied to Robinson's case. It emphasized that a guilty plea is an admission of guilt and limits the defendant's ability to appeal to issues that occurred at the time of the plea. The court found that Robinson's appeal did not raise any valid grounds for review, as he did not assert any specific wrongdoing related to the plea itself.

It is our opinion that the statute and our present rules reflect a codification of the existing case law which holds that a valid guilty plea conclusively disposes of all prior issues presented in the cause.

Conclusion

The Supreme Court affirmed the order of the District Court of Appeal, concluding that the appeal was properly dismissed as frivolous and that the statute in question is constitutional.

We conclude that a defendant's right to appeal from a guilty plea is limited to a class of issues which occur contemporaneously with the entry of the plea.

Who won?

The State prevailed in this case because the court upheld the dismissal of Robinson's appeal, affirming the constitutionality of the statute that limits appeals from guilty pleas.

We find the district court justified in summarily dismissing the appeal as frivolous on the record before it.

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