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Leal v. State

Citations: 595 So. 2d 274; 1992 Fla. App. LEXIS 2687; 1992 WL 48789Docket: No. 91-788

Court: District Court of Appeal of Florida; March 16, 1992; Florida; State Appellate Court

Narrative Opinion Summary

Louis Leal entered a nolo contendere plea to aggravated battery in March 1990, resulting in a sentence of one year probation, $380 in restitution, and supervision costs. In November 1990, a violation of probation affidavit was filed due to non-payment of restitution. After Leal denied the violation, the hearing was postponed to give him 60 more days to pay, yet no payments were made. In February 1991, it was agreed by Leal, the probation officer, and the State to terminate probation unsuccessfully, leading to a civil judgment for the restitution amount. The trial court, however, adjudicated Leal guilty of the felony, which was not part of the plea agreement. Leal appealed this adjudication, and the court found it invalid, referencing precedent cases. The judgment of conviction was reversed, and the case was remanded with instructions to either strike the adjudication or vacate the termination order, allowing Leal to defend against the alleged probation violation.

Legal Issues Addressed

Appellate Review of Trial Court's Adjudication

Application: Upon appeal, the court reversed the trial court's adjudication of guilt, deciding that it was not supported by the plea agreement or subsequent agreements related to probation violations.

Reasoning: Leal appealed this adjudication, and the court found it invalid, referencing precedent cases.

Effect of Nolo Contendere Plea on Adjudication of Guilt

Application: The court determined that an adjudication of guilt was inconsistent with the terms of the nolo contendere plea agreement entered by Louis Leal, which did not contemplate a felony conviction.

Reasoning: The trial court, however, adjudicated Leal guilty of the felony, which was not part of the plea agreement.

Modification of Probation Terms and Violation Proceedings

Application: The court found that the probation modification, which allowed for termination without successful completion, was agreed upon by all parties, but the adjudication of guilt was not warranted.

Reasoning: In February 1991, it was agreed by Leal, the probation officer, and the State to terminate probation unsuccessfully, leading to a civil judgment for the restitution amount.

Remand Instructions for Trial Court Regarding Adjudication

Application: The appellate court instructed the trial court to either strike the adjudication of guilt or vacate the termination order, allowing Leal to contest the probation violation allegations.

Reasoning: The judgment of conviction was reversed, and the case was remanded with instructions to either strike the adjudication or vacate the termination order, allowing Leal to defend against the alleged probation violation.