reservation requirement (Florida) · Go Syfert
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reservation requirement in Florida

6 Florida opinions name it 2 courts 1918–2025 1 in the last five years

The cases below were cited by Florida courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (4)

CaseFollowedCited
Hawk v. Stategreen
fladistctapp · 2003 · cited in 1 Florida opinions naming this issue, 2025–2025
1 sentence

2025See Pamphile v. State, 65 So. 3d 107, 108 (Fla. 4th DCA 2011) ("[W]ithout both an express reservation of the right to appeal and a finding that the issue is dispositive, . . . a defendant who pleads guilty or nolo contendere has no right to a direct appeal."); Hawk v. State, 848 So. 2d 475, 477-78 (Fla. 5th DCA 2003) (concluding that "the plea form . . . not contain[ing] any reservation of Hawk's right to appeal and his oral plea [being] entered without such a reservation" was "insurmountable" and precluded relief despite defense counsel having asked the trial court to make a finding that the

11
Edward Lewis v. State of Floridagreen
fladistctapp · 2018 · cited in 1 Florida opinions naming this issue, 2025–2025
1 sentence

2025See Pamphile v. State, 65 So. 3d 107, 108 (Fla. 4th DCA 2011) ("[W]ithout both an express reservation of the right to appeal and a finding that the issue is dispositive, . . . a defendant who pleads guilty or nolo contendere has no right to a direct appeal."); Hawk v. State, 848 So. 2d 475, 477-78 (Fla. 5th DCA 2003) (concluding that "the plea form . . . not contain[ing] any reservation of Hawk's right to appeal and his oral plea [being] entered without such a reservation" was "insurmountable" and precluded relief despite defense counsel having asked the trial court to make a finding that the

11
Pamphile v. Stategreen
fladistctapp · 2011 · cited in 1 Florida opinions naming this issue, 2025–2025
1 sentence

2025See Pamphile v. State, 65 So. 3d 107, 108 (Fla. 4th DCA 2011) ("[W]ithout both an express reservation of the right to appeal and a finding that the issue is dispositive, . . . a defendant who pleads guilty or nolo contendere has no right to a direct appeal."); Hawk v. State, 848 So. 2d 475, 477-78 (Fla. 5th DCA 2003) (concluding that "the plea form . . . not contain[ing] any reservation of Hawk's right to appeal and his oral plea [being] entered without such a reservation" was "insurmountable" and precluded relief despite defense counsel having asked the trial court to make a finding that the

11
City of Jacksonville v. Shaffer Et Ux.green
fla · 1932 · cited in 1 Florida opinions naming this issue, 1978–1978
2 sentences

1978See City of Jacksonville v. Shaffer, 107 Fla. 367 , 144 So. 888 (1932).

1978See City of Jacksonville v. Shaffer, 107 Fla. 367 , 144 So. 888 (1932).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Florida. Read the followed side critically anyway.

Also cited on this issue (4)

CaseCitedYears
Morrison v. Morrison green
fladistctapp · 1960
2 sentences

1965(Emphasis supplied) “Our decision in Morrison v. Morrison, Fla.App., 122 So.2d 199 (1960), supports this view concerning the reservation clause.

1963Our decision in Morrison v. Morrison, Fla.App., 122 So.2d 199 (1960), supports this view concerning the reservation clause.

21963–1965
Adams v. State green
fladistctapp · 1958
1 sentence

1982To support his claim that the partial reservation was error, Hitchcock cites Adams v. State, 102 So.2d 47 (Fla. 1st DCA 1958), and State v. Rolle, 202 So.2d 867 (Fla. 2d DCA 1967).

11982–1982
State v. Rolle neutral
fladistctapp · 1967
1 sentence

1982To support his claim that the partial reservation was error, Hitchcock cites Adams v. State, 102 So.2d 47 (Fla. 1st DCA 1958), and State v. Rolle, 202 So.2d 867 (Fla. 2d DCA 1967).

11982–1982
Hardman v. Brown green
wva · 1916
1 sentence

1918In Hardman v. Brown, West Va. , 88 S. E.

11918–1918

Where else courts name it

TX 95 (1926–2026) NY 44 (1871–2024) PA 27 (1905–2025) AL 24 (1871–1993) OH 23 (1876–2026) ND 22 (1951–2023) CA 20 (1885–2021) WA 18 (1893–2018) WV 15 (1907–2021) OK 15 (1924–2016) GA 10 (1925–2023) KY 9 (1912–1964) IL 9 (1943–2025) AR 8 (1897–2012) CO 8 (1959–2022) MS 7 (1953–2016) CT 6 (1931–2012) WI 6 (1890–2024) LA 6 (1965–2014) FL 6 (1918–2025) MA 6 (1870–2001) IN 5 (1871–1994) MT 5 (1909–2022) AZ 5 (1966–2004) WY 5 (1925–1987) OR 5 (1913–1984) NJ 5 (1927–2010) ID 4 (1978–2019) MI 4 (1892–2004) KS 4 (1905–2019) MD 4 (1992–2002) ME 4 (1973–2019) TN 3 (1925–1999) HI 3 (1905–2025) VT 3 (1911–2012) VA 3 (1881–2025) IA 3 (1929–2021) MN 3 (1943–1992) NM 3 (1966–2007) AK 3 (1987–1998) SD 3 (1949–2021) MO 3 (1903–2010) UT 2 (1982–2002) NC 2 (2009–2023) SC 2 (1952–1999)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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