Bolden v. State of Florida, 2D2023-2263

Calvin Terrell Bolden, Jr. entered into a plea agreement for a five-year sentence as a global resolution of four criminal cases, with three years minimum-mandatory.
Bolden requested a brief release before sentencing to get his affairs in order; the court allowed a two-day furlough on the condition he not be late, fail to appear, or get arrested.
Before sentencing, Bolden was arrested for battery related to a domestic dispute, and although ultimately no charges were filed, his arrest alone triggered breach of the court-imposed condition.
As a result of this violation, the court withdrew the five-year offer and imposed a much longer sentence—twenty years.
Bolden appealed, arguing error in sentencing due to the conditions of his presentencing release and challenged the propriety of imposing a longer sentence solely based on his arrest.
The appellate court affirmed the judgment but discussed concerns over the expanded use of "Quarterman agreements" beyond their original scope.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of sentencing terms post-arrest	Sentence should be limited to plea agreement terms; arrest alone shouldn’t justify harsher sentence	Violation of presentencing release conditions justifies departure from plea agreement	Affirmed longer sentence due to violation of release condition
Scope of Quarterman agreements	Expanded conditions ("don’t get arrested") are improper; only appearance should be required	Court allowed to set additional conditions as part of plea/furlough	Existing precedent allows court’s broader condition; but concerns noted
Breach of plea/furlough agreement	Breach should only occur if defendant fails to appear, not just due to arrest	Arrest breaches agreement, allowing any lawful sentence	Arrest as breach upheld
Appellate review of imposed sentence	Error for appellate review due to improper application of conditions	Sentence valid due to unchallenged violation and agreement terms	Affirmed, no appellate relief

Quarterman v. State, 527 So. 2d 1380 (Fla. 1988) (Established that presentencing release (Quarterman) agreements can permit withdrawal from a plea offer if the defendant fails to appear, and allows a court to impose a harsher sentence in that circumstance)
Neeld v. State, 977 So. 2d 740 (Fla. 2d DCA 2008) (Distinguished between conditions requiring appearance and broader behavioral conditions in Quarterman agreements)