MATTHEW MCRAE, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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Matthew McRae appealed the denial of his motion to correct an illegal sentence, seeking credit for time served in an Arkansas prison after a Florida detainer was placed on him. The court affirmed the trial court's denial and overruled the precedent in Mazza v. State, clarifying that defendants have no absolute entitlement to credit for time incarcerated outside Florida, though trial courts have discretionary authority to award such credit.
A defendant is not automatically entitled to credit for time incarcerated outside Florida when a detainer is placed. Trial courts have discretionary authority to award such credit, exercising that discretion based on whether the defendant was being held solely because of the Florida offense. The trial court's discretion is subject to a reasonableness test and must be supported by documentation or stated reasons.
[1] A defendant is entitled to credit for time spent incarcerated in Florida while awaiting transfer to the sentencing county if a detainer was placed on the defendant.
[2] A trial court has discretionary authority to award credit for time spent incarcerated outside of Florida while awaiting transfer to Florida.
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Join FLexlaw to unlock all legal intelligence“A trial court has discretionary authority to award credit for the time a defendant was incarcerated outside the state while awaiting transfer to Florida.”
Establishes that trial courts have discretion (not mandatory obligation) to award credit for out-of-state incarceration
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Join FLexlaw to unlock all legal intelligenceMcRae was incarcerated in an Arkansas prison when Florida placed a detainer on him. He filed a motion to correct his sentence seeking credit for the t…
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[*1049] EN BANC
WHATLEY, Judge.
Matthew McRae appeals the summary denial of his motion to correct illegal sentence filed pursuant to Florida Rule of Criminal Procedure 3.800(a). We affirm the trial court’s denial of the motion, but we recede from Mazza v. State, 804 So. 2d 613 (Fla. 2d DCA 2002), which McRae cited in his motion. Mazza holds that a defendant,is entitled to credit on a Florida prison sentence from the time a detainer was placed on the defendant while the defendant was in prison out of state. Different principles apply to giving credit depending on whether a defendant is incarcerated inside or outside of Florida when the detainer is lodged. Mazza mistakenly applied the wrong law.
A defendant is entitled to receive credit for time spent in jail in Florida if the sentencing county places a detainer on the defendant while the defendant is in another county’s jail. Bryant v. State, 787 So. 2d 68 (Fla. 2d DCA 2001). In Keene v. State, 816 So. 2d 819 (Fla. 2d DCA 2002), the court extended Bryant by applying it to detainers that are placed on a defendant while in a Florida prison. However, apart from the erroneous holding in Mazza, this entitlement has not been extended to incarceration outside the State of Florida.
A trial court has discretionary authority to award credit for the time a defendant was incarcerated outside the state while awaiting transfer to Florida. Kronz v. State, 462 So. 2d 450, 451 (Fla.1985); DeGeso v. State, 771 So. 2d 1264, 1265 (Fla. 2d DCA 2000). When deciding whether to award credit, “a trial court should consider whether the defendant was being held ‘solely because of the Florida offense for which he or she is being sentenced.’ ” DeGeso, 771 So. 2d at 1265 (quoting Kronz, 462 So. 2d at 451). This court has stated that the exercise of this discretion “is not unbridled but is subject to the test of reasonableness,” and when a trial court denies credit, the trial court must attach documentation or state the reasons for denying the credit. Heuton v. State, 790 So. 2d 1204, 1205 (Fla. 2d DCA 2001). Mazza overlooked the holding in Heuton. Thus, we recede from the portions of Mazza that imply an absolute entitlement to credit for time after the placement of a Florida detainer.on a defendant incarcerated outside the State of Florida.
The trial court exercised appropriate discretion in denying McRae the credit for time spent in an Arkansas prison, and we accordingly affirm.
BLUE, C.J., PARKER, ALTENBERND, FULMER, NORTHCUTT, GREEN, CASANUEVA, SALCINES, STRINGER, DAVIS, SILBERMAN, COVINGTON, and KELLY, JJ., Concur.
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Wombaugh v. State, 25 So. 3d 707 (Fla. 2d DCA 2010)…. . We note that when the postconviction court is deciding whether to award such credit, it should consider whether the defendant was being held in a different state solely for the Florida offense for which he is seeking credit. See McRae v. State, 820 So. 2d 1048, 1049 (Fla. 2d DCA 2002) (en banc). Furthermore, the exercise of the postconviction court’s discretion is not unbridled but is subject to the test of reasonableness. When the postconviction court denies a claim for out-of-slate jail credit, it must…
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Redding v. State, 848 So. 2d 417 (Fla. 2d DCA 2003)…robation. Redding claimed that he was held in Texas solely on the Florida warrant. In his motion, Redding requested jail time credit from October 15, 2001, until December 7, 2001. The trial court, in its order denying relief, cited McRae v. State, 820 So. 2d 1048 (Fla. 2d DCA 2002), asserting that the awarding of credit for time served out of state is within the sound discretion of the trial court. This is correct. However, McRae also held that the exercise of this discretion is not unbridled; when the trial…
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Glover v. State, 874 So. 2d 654 (Fla. 3d DCA 2004)…ated appeal and conclude that the trial court did not abuse its discretion when it declined to award the appellant credit for time served in a non-Florida jail on unrelated charges. See Kronz v. State, 462 So. 2d 450, 452 (Fla.1985); McRae v. State, 820 So. 2d 1048, 1049 (Fla. 2d DCA 2002) (en banc); Hopping v. State, 650 So. 2d 1087, 1088 (Fla. 3d DCA 1995). Accordingly, we affirm the order under review. Affirmed.…
Previewing 3 of 6 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Kronz v. State, 462 So. 2d 450 (Fla. 1985)
- Bryant v. State, 787 So. 2d 68 (Fla. 2d DCA 2001)
- DeGESO v. State, 771 So. 2d 1264 (Fla. 2d DCA 2000)
- Keene v. State, 816 So. 2d 819 (Fla. 2d DCA 2002)
- Carter D. Heuton v. State, 790 So. 2d 1204 (Fla. 2d DCA 2001)
- Mazza v. State, 804 So. 2d 613 (Fla. 2d DCA 2002)