Adams v. State

This case merits more than a citation to Robinson v. State, 373 So.2d 898 (Fla. 1979), as the basis for dismissing Adams’ appeal. An interesting procedural question is posed and it should be forthrightly answered: Is the proper method to present a claim that the trial court accepted a nolo contendere plea without determining that there is a sufficient factual basis for the plea (as required by Florida Rule of Criminal Procedure 3.170(j)) by direct appeal, or by filing a motion with the trial court pursuant to Florida Rule of Criminal Procedure 3.850? The majority holds that the only method to…