Perez v. State, 212 So. 3d 469

Perez pleaded guilty and was sentenced after charges arising from law-enforcement searches of his warehouse.
After sentencing, Perez moved to vacate his plea, judgments, and sentences, claiming newly-discovered evidence showed an illegal entry/seizure two days before the executed warrant.
Perez also alleged the State suppressed those documents in violation of Brady, arguing the materials would have changed suppression-hearing preparation and outcome and therefore amounted to a manifest injustice.
The trial court denied the motion in 2014, applying the then-controlling "manifest injustice/clear prejudice" standard and finding Perez failed to meet that burden and made no claim of actual innocence.
While this appeal was pending, the Florida Supreme Court in Long v. State announced a new two-prong standard for postconviction motions to vacate pleas based on newly discovered evidence.
The district court reversed and remanded for reconsideration under Long’s standard (trial court may but need not hold further evidentiary hearing).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Perez is entitled to vacatur of plea, judgment, and sentence based on newly-discovered evidence	The documents showed an earlier illegal entry/seizure; had defense known, suppression hearing and plea decision would differ	Trial court: Perez failed to show manifest injustice/clear prejudice and made no claim of actual innocence	Reversed and remanded for reconsideration under Long’s two-prong test
Whether the Brady doctrine applies to alleged suppression of the same evidence	State suppressed exculpatory documents that would have affected proceedings	State implicitly argued no prejudice under the old standard	Court noted Brady prejudice standard aligns with Long’s reasonable-probability test; treated under newly-discovered-evidence framework
Appropriate legal standard for motions to vacate pleas based on newly discovered evidence	Long standard applies and requires showing evidence was unknown and could not have been found with diligence, and a reasonable probability defendant would have insisted on trial	Trial court applied older manifest-injustice/clear-prejudice test	Court directed reconsideration using Long’s two-prong test
Need for further evidentiary hearing on remand	Perez argued the record warrants relief; he asserted first prong satisfied	State likely would prefer trial court discretion to deny without additional hearing	Court held remand for application of Long; trial court may but need not take more evidence

Long v. State, 183 So. 3d 342 (Fla. 2016) (adopts two-prong test for vacating plea based on newly discovered evidence)
Grosvenor v. State, 874 So. 2d 1176 (Fla. 2004) (two-prong ineffective-assistance test applied to guilty-plea context)
White v. State, 664 So. 2d 242 (Fla. 1995) (Brady prejudice/materiality measured by reasonable probability evidence would have changed result)
Perez v. State, 118 So. 3d 298 (Fla. 3d DCA 2013) (discusses manifest injustice/clear prejudice standard then applied)
Oce v. State, 742 So. 2d 464 (Fla. 3d DCA 1999) (no manifest injustice where no claim of actual innocence)
Brady v. Maryland, 373 U.S. 83 (U.S. 1963) (prosecution must disclose materially exculpatory evidence)