Christopher Wilburn v. State of Florida

Summary

The Third District Court of Appeal of Florida affirmed the circuit court's decision in Christopher Wilburn's appeal under Florida Rule of Appellate Procedure 9.141(b)(2). The court held that the plea colloquy, including the State's proffer and defense counsel's stipulation, satisfied the requirement for a factual basis for the plea.

Holdings

1. A trial court need not conduct a mini-trial to determine whether a plea has a factual basis; the factual-basis requirement may be satisfied through statements or admissions by the defendant, counsel, or prosecutor and other appropriate evidence or procedures, including a State proffer and defense counsel's stipulation during the plea colloquy.

Questions Presented

1. Whether the trial court adequately established a factual basis for the appellant's plea under Florida Rule of Criminal Procedure 3.172(a).

Disposition

affirmed