Saffold v. State
The Florida Supreme Court resolved a certified conflict between the Second and Fourth Districts over whether Florida Rule of Criminal Procedure 3.170(f)'s 'good cause' plea-withdrawal standard applies when a defendant's sentence is vacated on appeal and the case is remanded solely for resentencing. The Court held that rule 3.170(f) applies only to a defendant's original sentence, not to post-appeal resentencing, approving the Fourth District's decision in Saffold II and disapproving the Second District's contrary holding in Scott v. State.
Key facts
- Defendant's sentence was vacated on appeal and the case was remanded solely for resentencing, while the underlying conviction remained unchanged.
- The Second and Fourth Districts conflicted over whether Florida Rule of Criminal Procedure 3.170(f)'s 'good cause' standard applied to plea withdrawal during resentencing proceedings following appeal.
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Why it matters
This decision resolves a significant, recurring district split affecting any case where a sentence is vacated and remanded for resentencing but the underlying conviction is not disturbed. Criminal practitioners handling… — full analysis with a trial
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