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Nichols v. State

Citations: 876 So. 2d 1279; 2004 Fla. App. LEXIS 10571; 2004 WL 1584935Docket: No. 5D04-1817

Court: District Court of Appeal of Florida; July 16, 2004; Florida; State Appellate Court

Narrative Opinion Summary

Kevin Nichols was convicted of manslaughter with a firearm, a first-degree felony, after shooting and killing his victim, whose body he disposed of in the Halifax River. After an unsuccessful direct appeal, Nichols filed a Florida Rule of Criminal Procedure 3.850 motion, claiming his plea was involuntary. The trial court denied this motion since Nichols did not file a timely post-sentencing motion to withdraw his plea. Furthermore, any claims of involuntary pleas not supported by a prior motion must be based on ineffective assistance of counsel, which Nichols did not assert. The court affirmed the denial of the 3.850 motion but remanded the case to correct a clerical error in the judgment, ensuring it accurately reflects the conviction as a first-degree felony rather than a second-degree felony. The decision was affirmed and remanded for correction by Judges Sawaya, Palmer, and Orfinger.

Legal Issues Addressed

Correction of Clerical Error in Judgment

Application: The court remanded the case to correct a clerical error in the judgment to accurately reflect the conviction as a first-degree felony.

Reasoning: The court affirmed the denial of the 3.850 motion but remanded the case to correct a clerical error in the judgment, ensuring it accurately reflects the conviction as a first-degree felony rather than a second-degree felony.

Ineffective Assistance of Counsel Requirement

Application: Claims of involuntary pleas not supported by a prior motion must be based on ineffective assistance of counsel, which Nichols failed to assert.

Reasoning: Furthermore, any claims of involuntary pleas not supported by a prior motion must be based on ineffective assistance of counsel, which Nichols did not assert.

Involuntary Plea under Florida Rule of Criminal Procedure 3.850

Application: The court denied Nichols' motion claiming his plea was involuntary because he did not file a timely post-sentencing motion to withdraw his plea.

Reasoning: The trial court denied this motion since Nichols did not file a timely post-sentencing motion to withdraw his plea.