CHRISTOPHER WILBURN
v.
STATE OF FLORIDA
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A trial court may satisfy the factual basis requirement for a guilty plea through statements, admissions, and evidence presented during the plea colloquy, including the State's proffer and defense counsel's stipulation, without conducting a mini-trial.
[1] A trial court may establish the factual basis for a guilty plea through statements and admissions by the defendant, counsel, and prosecutor, as well as through factual ev…
Previewing 1 of 1 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“The inquiry to determine if a plea has a factual basis need not be a mini-trial[.]”
Woodbury v. State, 320 So. 3d 631, 650 (Fla. 2021)
Christopher Wilburn appealed from a judgment in Miami-Dade County following his guilty plea. The trial court accepted the plea based on the State's pr…
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Third District Court of Appeal State of Florida
Opinion filed December 31, 2025. Not final until disposition of timely filed motion for rehearing.
________________
No. 3D25-2015 Lower Tribunal No. F22-19244 ________________
Christopher Wilburn, Appellant,
vs.
State of Florida, Appellee.
An Appeal under Florida Rule of Appellate Procedure 9.141(b)(2) from the Circuit Court for Miami-Dade County, Milton Hirsch, Judge.
Christopher Wilburn, in proper person.
James Uthmeier, Attorney General, for appellee.
Before FERNANDEZ, GORDO and GOODEN, JJ.
PER CURIAM.
2 Affirmed. See Woodbury v. State, 320 So. 3d 631, 650 (Fla. 2021) (“The inquiry to determine if a plea has a factual basis need not be a minitrial[.]”) (internal quotation marks and citation omitted); Williams v. State, 316 So. 2d 267, 273 (Fla. 1975) (“We hold that the court may satisfy itself by statements and admissions made by the defendant, his counsel, and the prosecutor; by factual evidence heard or filed in the cause, i.e., preliminary hearings, motions to suppress, or depositions taken in the cause. . . . These are not the exclusive means for a trial court to reach a determination. The trial court is free to utilize whatever procedure is best for the particular case before it to ensure that the defendant is entering a plea to the proper offense under the facts of the case.”); Francis v. State, 121 So. 3d 67, 68-69 (Fla. 3d DCA 2013) (“The State’s proffer during the plea colloquy and defense counsel’s stipulation that there was a factual basis for the plea satisfied the factual basis requirement of Florida Rule of Criminal Procedure 3.172(a).”).
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Woodbury v. State, 320 So. 3d 631 (Fla. 2021)
- Francis v. State, 121 So. 3d 67 (Fla. 3d DCA 2013)