Jeromee Saffold v. State of Florida

Summary

The Supreme Court of Florida resolved a certified district-court conflict by holding that Florida Rule of Criminal Procedure 3.170(f)'s good-cause plea-withdrawal standard applies only before imposition of a defendant's original sentence and does not apply during post-appeal resentencing proceedings. Because de novo resentencing principles and the nullifying effect of sentence vacatur leave the underlying conviction completely intact, a defendant whose sentence is vacated on direct appeal cannot withdraw his plea for good cause before resentencing; the Court declined to infer an independent rules-based exception to longstanding principles of finality, scope of remand, and conviction validity. It approved the Fourth District's decision below and disapproved the Second District's contrary decision to the extent inconsistent. All justices concurred in the result, with a special concurrence emphasizing the court's authority over its own procedural rules and the absolute finality of an unappealed judgment of conviction.