WILLIAM M. YOUNG, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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William M. Young appealed the denial of his Rule 3.800(a) motion for jail credit. The court affirmed the denial because the record did not clearly establish that Young's Santa Rosa and Walton sentences were to run concurrently, which is a prerequisite for jail credit eligibility.
The court affirmed the denial of Young's jail credit motion because the motion and record do not affirmatively demonstrate that his sentences were concurrent. A defendant sentenced to consecutive sentences is not entitled to have jail time credit applied to each sentence.
[1] A motion for jail credit pursuant to Florida Rule of Criminal Procedure 3.800(a) must affirmatively allege that the court records demonstrate on their face an entitlement…
[2] A defendant is not entitled to have jail time credit pyramided by receiving credit on each sentence when sentences are imposed consecutively.
Previewing 2 of 4 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“because the record is clear in this case with regard to the amount of time spent in the Santa Rosa County Jail, as well as the fact that the Escambia and Santa Rosa sentences were to run concurrently”
The court contrasts this case with Travis v. State, where the record clearly established concurrent sentences, illustrating the requirement that the record must be clear regarding the nature of the sentences.
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Join FLexlaw to unlock all legal intelligenceYoung filed a motion for jail credit pursuant to Florida Rule of Criminal Procedure 3.800(a). Young had received sentences in both Santa Rosa and Walt…
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PER CURIAM.
William M. Young appeals the denial of his claim for jail credit filed pursuant to Florida Rule of Criminal Procedure 3.800(a).
Because it is not clear from Young’s motion (or the record) that his Santa Rosa and Walton sentences were to run concurrently, we affirm the order on appeal. Cf. Travis v. State, 724 So. 2d 119 (Fla. 1st DCA 1998) (reversing and remanding denial of 3.800(a) motion for jail credit “[bjecause the record is clear in this case with regard to the amount of time spent in the Santa Rosa County Jail, as well as the fact that the Escambia and Santa Rosa sentences were to run concurrently”).
If Young’s sentences were to run consecutively, rather than concurrently, he would not be entitled to credit for the time he served in Santa Rosa. See Daniels v. State, 491 So. 2d 543, 545 (Fla.1986) (explaining that where a defendant does not receive concurrent sentences on multiple charges, the defendant is not entitled to have jail time credit pyramided by receiving credit on each sentence); Knight v. State, 517 So. 2d 87, 88 (Fla. 1st DCA 1987) (explaining that defendant who was sentenced on substantive charge and who was also sentenced for violating his probation, with the sentence for violation of probation to run consecutively to the sentence on the substantive charge, was not entitled to jail credit on each of his consecutive sentences but only to credit for time served against sentence for substantive charge).
Accordingly, because Young’s motion does not indicate that his sentences were concurrent, it fails to affirmatively allege that “the court records demonstrate on their face an entitlement to relief.” See State v. Mancino, 714 So. 2d 429, 433 (Fla.1998); Baker v. State, 714 So. 2d 1167 (Fla. 1st DCA 1998)
AFFIRMED.
KAHN, WEBSTER and VAN NORTWICK, JJ., CONCUR.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- State v. Mancino, 714 So. 2d 429 (Fla. 1998)
- Daniels v. State, 491 So. 2d 543 (Fla. 1986)
- Williamson v. Penni Lane Williamson, 714 So. 2d 1167 (Fla. 3d DCA 1998)
- Baker v. State, 714 So. 2d 1167 (Fla. 1st DCA 1998)
- Travis v. State, 724 So. 2d 119 (Fla. 1st DCA 1998)
- COX v. State, 517 So. 2d 87 (Fla. 1st DCA 1987)