Angel Daniel Caraballo v. State of Florida
Docket 6D2024-0099
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- Filed
- Jurisdiction
- Florida
- Court
- District Court of Appeal of Florida
- Type
- Opinion
- Case type
- Criminal Appeal
- Disposition
- Reversed
- Docket
- 6D2024-0099
Appeal from denial of a rule 3.800(a) motion challenging the sentencing documents in a criminal case
Summary
The Sixth District Court of Appeal reversed a trial court order that denied Angel Daniel Caraballo’s Florida Rule of Criminal Procedure 3.800(a) motion challenging the form of his life sentences. The court agreed with the State that the judgments were defective because they failed to state Caraballo’s parole eligibility. The panel remanded with instructions that the trial court amend both life sentences to specify parole eligibility after the 25-year mandatory minimum. The amendments are ministerial and do not require Caraballo’s presence.
Issues Decided
- Whether the trial court’s written life-sentence judgments correctly reflected the defendant’s parole eligibility
- Whether the sentencing documents can be corrected ministerially on remand without the defendant’s presence
Court's Reasoning
The court accepted the State’s concession that the life-sentence judgments omitted language stating parole eligibility after the 25-year mandatory minimum, rendering the sentences legally defective in form. Because the error was clerical in nature and did not require re-sentencing, the proper remedy was to reverse the denial of the 3.800(a) motion and direct the trial court to amend the judgments to include the parole-eligibility language. The court emphasized that these corrections are ministerial and therefore do not require the defendant to appear.
Parties
- Appellant
- Angel Daniel Caraballo
- Appellee
- State of Florida
- Judge
- Tanya Davis Wilson
- Attorney
- James Uthmeier, Attorney General
- Attorney
- Rebecca Rock McGuigan, Assistant Attorney General
Key Dates
- Decision date
- 2026-05-01
What You Should Do Next
- 1
Trial court to amend judgments
The trial court should enter amended sentencing orders for counts one and two stating parole eligibility after completion of the 25-year mandatory minimum term.
- 2
No defendant appearance required
The clerk and judge should note that the corrections are ministerial and proceed without requiring Caraballo to be present.
- 3
File rehearing or further review if desired
If a party wishes to challenge the district court’s decision, they should consult counsel and timely file a motion for rehearing or seek higher appellate review under applicable rules and deadlines.
Frequently Asked Questions
- What did the court decide?
- The appellate court reversed the trial court’s denial of a motion and ordered the written life sentences corrected to show parole eligibility after 25 years.
- Who is affected by this decision?
- Angel Daniel Caraballo is directly affected because his sentencing documents will be amended; the State is affected insofar as it must implement the correction.
- Does this change the length of the sentence?
- No. The decision does not change the life sentences or the 25-year mandatory minimum; it only corrects the written judgments to reflect existing parole eligibility.
- Will Caraballo have to appear in court for the correction?
- No. The court said the corrections are ministerial and do not require Caraballo’s presence.
- Can this decision be appealed further?
- Possibly, but the opinion does not address further appeals; standard appellate timeframes for seeking rehearing or higher review would apply.
The above suggestions and answers are AI-generated for informational purposes only. They may contain errors. NoticeRegistry assumes no responsibility for their accuracy. Consult a qualified attorney before relying on them.
Full Filing Text
SIXTH DISTRICT COURT OF APPEAL
STATE OF FLORIDA
_____________________________
Case No. 6D2024-0099
Lower Tribunal No. 2007-CF-004511
_____________________________
ANGEL DANIEL CARABALLO,
Appellant,
v.
STATE OF FLORIDA,
Appellee.
_____________________________
Appeal pursuant to Fla. R. App. P. 9.141(b)(2) from the Circuit Court for Osceola County.
Tanya Davis Wilson, Judge.
May 1, 2026
PER CURIAM.
Angel Daniel Caraballo appeals the trial court’s order denying his rule
3.800(a) motion and argues that his sentences on counts one and two are illegal
because both fail to reflect his parole eligibility. The State concedes error. We
agree.
Therefore, we reverse the trial court’s order denying Caraballo’s motion and
remand for the trial court to amend both the life sentence on count one and the life
sentence on count two to state that Caraballo is eligible for parole after completing
the 25-year mandatory minimum term. Caraballo’s presence is not required for
those ministerial corrections.
REVERSED and REMANDED with instructions.
WOZNIAK, WHITE and GANNAM, JJ., concur.
Angel Daniel Caraballo, Avon Park, pro se.
James Uthmeier, Attorney General, Tallahassee, and Rebecca Rock McGuigan,
Assistant Attorney General, Daytona Beach, for Appellee.
NOT FINAL UNTIL TIME EXPIRES TO FILE MOTION FOR REHEARING
AND DISPOSITION THEREOF IF TIMELY FILED
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