Stanley Tyron Harris v. State of Florida

Summary

The First District Court of Appeal of Florida affirmed the denial of Stanley Tyron Harris’s presentence motion to withdraw his guilty plea to third-degree murder and discharging a firearm from a vehicle. The court also affirmed the sentencing procedure, holding that the trial court acted within its discretion in excluding defense expert testimony it deemed irrelevant to the negotiated sentence.

Holdings

1. The trial court did not abuse its discretion in denying Harris's presentence motion to withdraw his guilty plea because Harris failed to establish good cause. The trial court reasonably found that his claimed misunderstanding was not credible, that the trajectory analysis was not newly discovered, and that his alleged reliance on the prosecutor's factual-basis statement was inconsistent with his admission that he had agreed to the plea beforehand.
2. The trial court did not abuse its discretion by refusing to hear defense-expert testimony about whether Harris fired the fatal bullet because the evidence was not relevant to the negotiated sentence and the court had no discretion to deviate from the agreed-upon term.

Questions Presented

1. Whether the trial court abused its discretion by denying Harris's presentence motion to withdraw his negotiated guilty plea under Florida Rule of Criminal Procedure 3.170(f).
2. Whether the trial court erred by declining to hear defense-expert testimony concerning whether Harris's firearm fired the fatal bullet during sentencing.

Disposition

affirmed