Joseph M. Moody v. State, 210 So. 3d 748

Defendant Joseph Moody was charged with multiple sexual offenses involving a minor; he pleaded nolo contendere to reduced charges (two counts of child abuse) and received consecutive five-year probationary terms.
The State's initial discovery notice stated there was no Brady material; the day after sentencing the State produced supplemental discovery disclosing prior Brady information concerning an alleged abuse report against the victim's stepmother, who was a State witness.
Defense alleged the delayed disclosure prevented investigation into potential impeachment or exculpatory evidence related to the stepmother and the minor victim, and asserted the plea was involuntary because he would have gone to trial if aware of the information.
The trial court summarily denied the post-sentencing motion to withdraw the plea as facially insufficient and entered the denial with prejudice, without holding an evidentiary hearing.
The defendant appealed, arguing he was entitled to an evidentiary hearing because an involuntary plea resulting from a Brady violation can constitute manifest injustice.

Issue	Moody's Argument	State's Argument	Held
Whether Moody's post-sentencing motion to withdraw plea was facially sufficient to require an evidentiary hearing	The delayed Brady disclosure rendered his plea involuntary and caused manifest injustice; he would have gone to trial	The motion was facially insufficient and did not warrant an evidentiary hearing	Court reversed: the motion was facially sufficient and an evidentiary hearing is required
Whether an involuntary plea can constitute manifest injustice post-sentencing	An involuntary plea (due to withheld Brady material) is a manifest injustice warranting withdrawal	Denied motion as legally deficient; no manifest injustice shown	Court held that involuntary plea qualifies as manifest injustice under precedent
Whether the trial court may consider only the existing record when adjudicating involuntariness claims	The court must consider evidence beyond the trial record to determine voluntariness	Trial court declined to hold a hearing and relied on facial insufficiency	Court held an evidentiary hearing is required to consider evidence beyond the record
Standard of review for denial of motion to withdraw plea	Motion denial reviewed for abuse of discretion; facial sufficiency triggers hearing	Same standard; argued motion failed that threshold	Court applied abuse-of-discretion standard and found the trial court abused its discretion by denying without a hearing

Brady v. Maryland, 373 U.S. 83 (1963) (prosecutor must disclose materially exculpatory or impeaching evidence)
Griffin v. State, 114 So. 3d 890 (Fla. 2013) (denial of motion to withdraw plea reviewed for abuse of discretion)
Newsome v. State, 877 So. 2d 938 (Fla. 2d DCA 2004) (Brady-based claim can render a plea facially sufficient to warrant an evidentiary hearing)
Partlow v. State, 840 So. 2d 1040 (Fla. 2003) (entry of an involuntary plea constitutes manifest injustice)
Johnson v. State, 60 So. 3d 1045 (Fla. 2011) (adjudication of plea voluntariness requires evidentiary hearing considering evidence beyond trial record)
Panchu v. State, 1 So. 3d 1243 (Fla. 4th DCA 2009) (post-sentencing plea-withdrawal requires proof of manifest injustice)
Hernandez v. State, 204 So. 3d 128 (Fla. 4th DCA 2016) (reaffirming requirement of evidentiary hearing for involuntariness claims)