Proffitt v. State
The Sixth DCA affirmed Proffitt's drug trafficking convictions and sentence, rejecting her claim that the trial court imposed a vindictive sentence after she rejected the State's plea offer and proceeded to trial. Applying the Wilson v. State factors, the court held the trial judge's pre-trial questioning about the status of plea negotiations did not amount to improper judicial initiation of or participation in plea bargaining, and the disparity between the rejected offer and the ultimate sentence, without more, did not create a presumption of vindictiveness.
Key facts
- Proffitt was convicted of drug trafficking after rejecting a pre-trial plea offer and proceeding to trial.
- The trial court questioned the parties about plea negotiations status and confirmed Proffitt's rejection of the State's offer.
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Why it matters
This opinion provides a useful, practitioner-ready roadmap for evaluating vindictive-sentencing claims under the Wilson factors, clarifying that routine judicial inquiries into plea status (as opposed to court-initiated… — full analysis with a trial
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