Sanchez v. State
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.
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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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