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3rd DCASeptember 18, 2024Affirmed⭐ Notable

Sanchez v. State

Case No. 3D2022-2097

Appellant sought to withdraw a 1996 guilty plea under Rule 3.170(l) after the trial court, in 2022, struck a mandatory-minimum condition on an already-served sentence for grand theft of a motor vehicle because that offense was not enumerated under section 775.087(2). The Third DCA affirmed denial of the motion, holding that the ministerial correction of a technical sentencing error on a completed sentence did not constitute a new 'rendition of sentence' that restarts the 30-day deadline under Rule 3.170(l), and that Appellant failed to show manifest injustice warranting plea withdrawal 26 years later.

Key facts

  • Appellant pleaded guilty in 1996 to grand theft of a motor vehicle and received a sentence with a mandatory-minimum condition.
  • In 2022, the trial court struck the mandatory-minimum condition as a technical error because the offense was not enumerated under section 775.087(2), while appellant continued serving other concurrent sentences.
  • +2 more key facts with a free trial

Why it matters

This opinion clarifies that a later ministerial correction striking an improper mandatory-minimum condition on a sentence already served does not reset the Rule 3.170(l) clock for withdrawing a plea, even where other… — full analysis with a trial

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