State v. Billiter
Annotate this CaseIn this case, the Supreme Court was asked to resolve a certified conflict between the fifth and second district courts of appeals on whether res judicata bars a criminal defendant from arguing that his plea is void due to an earlier postrelease-control sentencing error when the defendant has entered a plea of guilty to escape. The Supreme Court held that if a trial court improperly sentences a defendant to a term of postrelease control and the defendant subsequently pleads guilty to violating the terms of that postrelease control, the defendant is not barred by principles of res judicata from collaterally attacking his conviction as void. In so holding, the Court reversed the judgment of the fifth district court of appeals, which affirmed the trial court's denial of Defendant's motion to withdraw his guilty plea to escape on the theory that he had never been legally placed on postrelease control.
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