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[florida] Does A Juvenile Guilty Plea That Was Later Vacated Under A Walker/rehabilitation Plan Count As “entering A Plea” For Professional Licensing Under F.s. §464.018?

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Location: Florida

Hi Redditors of law,

I’m looking for help interpreting a fairly narrow Florida administrative/professional licensing issue. I’m not asking anyone to predict whether the Board of Nursing will approve my application.

When I was 14, I had several juvenile delinquency cases in Florida. I entered a Walker/Rehabilitation Plan under Florida juvenile procedure.

The written agreement provided that I would enter guilty pleas to several charges, including F.S. §784.048(5) and §836.10, but that the pleas would be held in abeyance while I completed the rehabilitation plan.

The agreement specifically states:
“Upon successful completion of the terms and conditions herein, the plea shall be vacated and the charges dismissed.”

I successfully completed the entire program. The juvenile court subsequently entered an Order of Dismissal based on successful completion, terminated supervision, dismissed the cases, and discharged me from further responsibility regarding the charges. The juvenile record is now sealed.
I am now in nursing school and eventually intend to apply for RN licensure by examination in Florida.

My question concerns Florida Statute §464.018(1)(d) and (e).

Those provisions make certain criminal dispositions grounds for denial of a nursing license and use language along the lines of being convicted/found guilty or “entering a plea of guilty or nolo contendere,” regardless of adjudication.

I understand why an existing guilty plea with adjudication withheld would still fall within that language. My situation seems different because the plea itself was subsequently vacated by operation of the rehabilitation agreement, followed by dismissal of the underlying juvenile charges.

So my specific legal question is:

Does the historical act of entering the guilty plea remain an “entered plea” for purposes of §464.018(1)(d)/(e) after that plea has been judicially vacated pursuant to successful completion of a juvenile Walker/Rehabilitation Plan?

Or, alternatively, does the vacatur mean there is no longer a legally operative guilty plea capable of satisfying §464.018, even though I would still need to disclose the historical case if the licensing application asks whether I have ever entered a plea?

I’m particularly interested in any Florida appellate cases, DOAH recommended/final orders, Board of Nursing final orders, Attorney General opinions, or analogous Florida professional-licensing decisions dealing with a withdrawn or vacated plea rather than merely a withhold of adjudication.

I have looked at §[456.0635](tel:456.0635) as a possible analogy because that health-profession licensing statute also uses “entered a plea of guilty or nolo contendere…regardless of adjudication” language while expressly recognizing circumstances involving a subsequently withdrawn plea/dismissed charges. I’m unsure how much interpretive weight that carries for §464.018.

I’m not asking whether the sealed record will appear on a background check, whether I should disclose it, or whether the Board has discretion to deny a license for other reasons. I’m specifically trying to understand the legal effect of the vacated plea on the “entered a plea” language of §464.018(1)(d)/(e).

If anyone practices Florida administrative/professional licensing law or knows of controlling or persuasive authority addressing this distinction, I would greatly appreciate any discussion on this.

submitted by /u/Big-Balance-5616
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