Law360 (September 10, 2026, 9:19 PM EDT) -- A Florida state appeals court has reversed a teenager's manslaughter conviction and sentence, finding the teen's attorney let him enter an open plea without telling him that his statements to police potentially could have been suppressed for Miranda rule violations.

A three-judge panel of the Second District Court of Appeal ruled Wednesday that a trial court erred when it denied Emmanuel Ruiz's motion to withdraw his plea because his former counsel testified that he had never advised Ruiz on the possibility of filing a motion to suppress his statements.

"On this record, Ruiz was wholly unaware of the possibility of suppressing his statements and established good cause to withdraw his plea to his manslaughter with a firearm case," Judge John Guard wrote in an opinion for the panel.

In August 2023, Ruiz was separately charged with manslaughter with a firearm and carrying a concealed firearm. He was 16 at the time of the crimes alleged by prosecutors.

Ruiz's then-defense counsel did not tell his client about the possibility of seeking suppression, even though he believed there was a basis to suppress his statements under Miranda, according to the opinion. The lawyer later testified that when they first met, Ruiz told him he did not want a trial, and filing a suppression motion would have run counter to that direction, the panel said.

Ruiz entered open pleas in both cases in August 2024. But on Dec. 30, 2024, he filed a motion to withdraw his pleas.

In April and May 2025, the trial court held an evidentiary hearing on his motion to withdraw his pleas. The lower court denied his motion and sentenced him to 20 years in prison, followed by a year of community control and six years of probation.

On Wednesday, Judge Guard wrote that courts must allow a no-contest plea to be withdrawn anytime before sentencing if good cause exists — including when a defendant's plea is made in ignorance.

"We have held repeatedly that entry of a plea relying on mistaken advice constitutes good cause and supports withdrawal of a plea," the panel's opinion read.

The judges also pointed to Nicol v. State, a Fifth District case from 2005 that held that failure to advise a defendant of a possible motion to suppress incriminating statements to police is good cause for withdrawing a plea.

"We want to make clear that we agree with Nicol that in deciding a motion to withdraw a plea for failing to advise regarding a motion to suppress the likelihood of success of a motion to suppress is not relevant," the panel said. "Instead, the trial court should only consider whether the defendant is acting on misapprehension or ignorance on that issue."

However, the appeals court affirmed Ruiz's conviction and sentence for carrying a concealed firearm.

Representatives of the parties could not immediately be reached for comment Thursday afternoon.

Judges John Guard, Patricia Kelly and Anthony Black sat for the Second District Court of Appeal.

Ruiz is represented by Blair Allen and Ronald Toward of the Office of the Public Defender for Florida's Tenth Judicial Circuit.

The government is represented by James Uthmeier and Tayna Alexander of the Florida Attorney General's Office.

The case is Ruiz v. State of Florida, case number 2D2025-2118, in the Second District Court of Appeal of the State of Florida.

--Editing by Covey Son.

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