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5th DCAAugust 16, 2024Affirmed⭐ Notable

Jones v. State

Case No. 5D2023-2311

Jones appealed a 24-year sentence imposed after he failed to appear for sentencing under a Quarterman agreement that had promised a five-year sentence. The Fifth DCA affirmed, holding that Jones's argument that his non-appearance was not willful was unpreserved because trial counsel argued only for leniency rather than objecting that the trial court could not depart from the agreed sentence absent a finding of willful breach.

Key facts

  • Jones was sentenced to 24 years after failing to appear for sentencing under a Quarterman agreement that had promised a five-year sentence.
  • At sentencing, trial counsel argued for leniency but did not specifically object that the trial court lacked authority to depart from the agreed sentence without a finding of willful breach.
  • +1 more key fact with a free trial

Why it matters

This opinion, especially the lengthy concurrence, provides practical guidance on Quarterman agreement litigation: it reiterates that willfulness is required to void such an agreement, that the State bears the burden of… — full analysis with a trial

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