AARON LEE YOUNG, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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Aaron Lee Young appeals the denial of his motion for jail credit, claiming he was incarcerated in Hillsborough County jail while participating in an in-house drug treatment program for six months but received no credit for that time. The court reverses and remands, holding that while defendants generally are not entitled to credit for time in live-in drug treatment programs, Florida law requires credit when the defendant is incarcerated in county jail participating in a jail drug treatment program.
A defendant is entitled to jail credit for time spent incarcerated in a county jail while participating in the jail's drug treatment program, as required by the plain language of Florida Statutes section 921.161, even though defendants generally are not entitled to credit for time in live-in drug treatment programs unconnected to county jail incarceration.
[1] A defendant is entitled to jail credit for time spent incarcerated in a county jail, even if participating in a jail-based drug treatment program.
[2] A trial court must address a defendant's claim of jail credit for time spent in a jail-based drug treatment program when court records support the claim.
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Join FLexlaw to unlock all legal intelligence“While the trial court is correct that a defendant is generally not entitled to credit for time spent in a live-in drug treatment program, see Pennington v. State, 398 So.2d 815 (Fla.1981) a different result is compelled by the plain language of section 921.161, Florida Statutes (1999), when the defendant is incarcerated in the county jail and participating in a jail drug treatment program.”
Establishes the core holding that jail credit is required for county jail incarceration during jail drug treatment programs despite the general rule to the contrary.
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Join FLexlaw to unlock all legal intelligenceYoung was ordered to enter and complete an in-house jail drug treatment program with his residency at Hillsborough County jail for six months. A case …
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[*129] PER CURIAM.
Aaron Lee Young appeals the summary denial of his motion for additional jail credit filed pursuant to Florida Rule of Criminal Procedure 3.800(a). Young alleges that the court records reflect on their face that he did not receive credit for six months that he spent incarcerated in the Hillsborough County jail participating in an in-house drug treatment program. The trial court denied the claim, stating that Young was not entitled to credit for time spent in an inpatient drug treatment facility. The trial court did not address or attempt to refute Young’s claim that he was incarcerated in the county jail for the length of the drug treatment program, and, in fact, the records attached by the trial court support Young’s claim. A case progress log shows that Young was ordered to enter and complete the in-house jail drug treatment program and that his residency was to be at the Hillsborough County jail for six months. The log also reveals that the court issued a commitment order. While the trial court is correct that a defendant is generally not entitled to credit for time spent in a live-in drug treatment program, see Pennington v. State, 398 So. 2d 815 (Fla.1981) a different result is compelled by the plain language of section 921.161, Florida Statutes (1999), when the defendant is incarcerated in the county jail and participating in a jail drug treatment program. Because the trial court’s order failed to address Young’s claim that he was incarcerated while completing the drug treatment program and the attached records do not refute it,1 we reverse and remand for further proceedings.
On remand, the trial court shall determine whether the court records2 demonstrate that Young was actually incarcerated in the county jail while completing the jail’s drug treatment program. If such a determination requires an evidentiary hearing and cannot be made from the face of the records, the trial court may again deny Young relief. See State v. Mancino, 714 So. 2d 429 (Fla.1998). Ordinarily, such a denial would have to be without prejudice to Young seeking relief pursuant to rule 3.850. However, in this case it appears that the time has elapsed for Young to file a motion pursuant to that rule.
Reversed and remanded.
FULMER, A.C.J., and GREEN and DAVIS, JJ.,
. The State Credit Time Log with the notation “stip. credit 55 days” and no information regarding the dates that Young was in the county jail does not conclusively refute his allegation.
. The trial court may consider jail records in making this determination. See Hidalgo v. State, 729 So. 2d 984 (Fla. 3d DCA 1999).
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Hamilton v. State, 898 So. 2d 172 (Fla. 4th DCA 2005)…carceration.” Pennington, 398 So. 2d at 817. Of course, credit must be awarded for time spent in an in-house drug treatment program that was part of defendant’s confinement in jail before trial, after conviction, or in state prison. Young v. State, 754 So. 2d 128 (Fla. 2d DCA 2000). The first district has followed Pennington and refused to allow credit for time spent in drug' rehab. Calhoun v. State, 403 So. 2d 1082 (Fla. 1st DCA 1981); Williamson v. State, 765 So. 2d 89 (Fla. 1st DCA 2000). The third distr…
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Tennell v. State, 787 So. 2d 65 (Fla. 2d DCA 2001)…was entitled to credit against his prison sentence for time served in a drug treatment center as a condition of community control. A defendant is generally not entitled to jail credit for time spent in a live-in treatment center. See Young v. State, 754 So. 2d 128 (Fla. 2d DCA 2000). However, a defendant is entitled to credit where the live-in treatment center is the functional equivalent of jail. See Hill v. State, 754 So. 2d 788 (Fla. 2d DCA 2000). Tennell presented a facially sufficient claim detailing tha…
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Clinesmith v. State, 775 So. 2d 399 (Fla. 2d DCA 2000)…annot be decided on the face of the record but requires an evidentiary hearing, it may deny the motion but that denial shall be without prejudice to Clinesmith filing a motion pursuant to Florida Rule of Criminal Procedure 3.850. See Young v. State, 754 So. 2d 128 (Fla. 2d DCA 2000). Reversed and remanded. PARKER, A.C.J., and CASANUEVA and GREEN, JJ., Concur.…
Previewing 3 of 5 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- State v. Mancino, 714 So. 2d 429 (Fla. 1998)
- Hidalgo v. State, 729 So. 2d 984 (Fla. 3d DCA 1999)
- Doretha Pennington v. State, 398 So. 2d 815 (Fla. 1981)