WAYNE JESSIE STEPHENS
v.
STATE OF FLORIDA

Fla. 5th DCA | 2025-08-15
No. 2025-1020
Sacks, J., Makar, J., Lambert, J., Harris, J.
2025 FL 7084 Florida District Court of Appeal, Fifth District (2025)

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Holding

A trial court's oral pronouncement of sentence prevails over a conflicting written sentence, and clerical errors in written judgments must be corrected on remand.


Headnotes

[1] When a conflict exists between the oral pronouncement of sentence by a trial court and the written judgment, the oral pronouncement prevails and the written judgment must…

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Key Quotes

“Thus, when conflict arises between the written sentence and the [trial court's] oral pronouncement, the oral pronouncement prevails.”

Citation to Ashley v. State, 850 So. 2d 1265, 1268 (Fla. 2003), establishing the rule that oral pronouncements control over written sentences.

Facts & Procedural History

Wayne Jessie Stephens entered an open guilty plea to a charged offense in Duval County Circuit Court. The trial court imposed a sentence but the writt…

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Per_curiam
Per Curiam

FIFTH DISTRICT COURT OF APPEAL

STATE OF FLORIDA

_____________________________

Case No. 5D2025-1020 LT Case No. 16-2024-CF-8431-A _____________________________

WAYNE JESSIE STEPHENS,

Appellant,

v.

STATE OF FLORIDA,

Appellee. _____________________________

On appeal from the Circuit Court for Duval County. Jonathan D. Sacks, Judge.

Matthew J. Metz, Public Defender, and Allison A. Havens, Assistant Public Defender, Daytona Beach, for Appellant.

James Uthmeier, Attorney General, and Amanda Bosman, Assistant Attorney General, Tallahassee, for Appellee.

August 15, 2025

PER CURIAM.

In this appeal proceeding under Anders v. California, 386 U.S. 738 (1967), we affirm the judgment and sentence imposed by the trial court following Appellant’s open, guilty plea to the charged offense. However, we remand with directions to the trial court to enter an amended judgment to correct a clerical error in the written sentence to show that Appellant was awarded 199 days of

2 jail credit. See Ashley v. State, 850 So. 2d 1265, 1268 (Fla. 2003) (“Thus, when conflict arises between the written sentence and the [trial court’s] oral pronouncement, the oral pronouncement prevails.”).

AFFIRMED, REMANDED with directions.

MAKAR, LAMBERT, and HARRIS, JJ., concur.

_____________________________

Not final until disposition of any timely and authorized motion under Fla. R. App. P. 9.330 or 9.331. _____________________________


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