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5th DCAMay 30, 2025Reversed and Remanded⭐ Notable

Williams v. State

Case No. 5D2024-2941

Williams sought postconviction relief after discovering that his negotiated time-served sentence was based on an erroneous scoresheet and an incorrect, overstated amount of jail credit. The Fifth District reversed the summary denial of his 3.850 motion, holding the record did not conclusively refute his claim and that an evidentiary hearing was required to determine whether the trial court would have imposed the same sentence had it known the true facts.

Key facts

  • Williams was convicted and accepted a negotiated plea agreement for a time-served sentence based on a scoresheet and jail credit calculation provided by the trial court.
  • After sentencing, Williams discovered the scoresheet contained errors and his jail credit was miscalculated and overstated, undermining the factual basis for his agreed sentence.
  • +2 more key facts with a free trial

Why it matters

This opinion usefully reaffirms and applies the distinction between the 3.800(a) 'could have imposed the same sentence' standard and the stricter 3.850 'would have imposed the same sentence' standard, which is a… — full analysis with a trial

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