Johnson v. State
60 So. 3d 1045
| Fla. | 2011Background
- Johnson and Joyner challenged credit-for-time-served provisions in plea agreements via Florida Rule of Criminal Procedure 3.800(a).
- Third District denied relief, holding the time-served credit waiver precluded additional credit.
- This Court acknowledged a conflict with the Fifth District’s Davis decision and granted jurisdiction to resolve it.
- Rule 3.800(a) requires relief when the court records facially demonstrate entitlement; it does not adjudicate claims to voluntary plea validity.
- Claimants sought credit beyond the agreement’s terms; they did not allege involuntary pleas on the record for 3.800(a) relief.
- Court disapproved Davis and held 3.800(a) cannot provide relief for challenges to plea-credit provisions; other routes exist for involuntariness claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Can 3.800(a) review challenge plea credit waivers? | Johnson/Joyner argued 3.800(a) permits relief for unwarranted credit denial. | State argued 3.800(a) requires facial entitlement on the record; waivers bar extra credit. | No; 3.800(a) relief not cognizable for such waivers. |
| Do plea-credit provisions foreclose additional time credit? | Johnson/Joyner contended records did not conclusively prove valid waivers. | Waivers validly limit entitlement to time-served credit. | Waivers may preclude claims not provided in the agreement. |
| Was the claim properly before the court under 3.800(a)? | Claims fall under 3.800(a) to obtain additional credit. | 3.800(a) cannot adjudicate voluntariness or non-face claims. | No; not cognizable on the face of the record. |
| Are 3.850 or 3.170(0) available to challenge plea terms? | Alternative routes could undo or modify plea terms. | These rules do not rewrite plea agreements. | Yes; these are proper avenues for involuntariness or collateral relief. |
| Should Davis be upheld or disapproved? | Davis supports 3.800(a) challenge to credit provisions. | Davis is in conflict with other district decisions. | Disapproved; Johnson/Joyner affirmed while disallowing Davis. |
Key Cases Cited
- Davis v. State, 968 So.2d 1051 (Fla. 5th DCA 2007) (held plea credit provisions may be challenged under 3.800(a))
- Johnson v. State, 974 So.2d 1152 (Fla. 3d DCA 2008) (plea credit waiver effectively precludes additional credit)
- Joyner v. State, 988 So.2d 670 (Fla. 3d DCA 2008) (similar to Johnson; 3.800(a) not cognizable for such claims)
- Williams v. State, 957 So.2d 600 (Fla. 2007) (face-of-record entitlement standard for 3.800(a))
- Brooks v. State, 969 So.2d 238 (Fla. 2007) (3.800(a) requires no evidentiary hearing; burden on movant)