STEVEN T. YOUNG, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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Steven Young appealed the denial of his motion for jail credit under Florida Rule of Criminal Procedure 3.800(a). The appellate court reversed and remanded because the trial court failed to adequately address whether Young was entitled to credit for time spent in Palm Beach County jail before being transferred to Manatee County.
The court reversed and remanded, holding that nothing in the record indicates the Palm Beach County jail time was calculated into the 247 days awarded, and the trial court must reconsider whether Young is entitled to credit for that time. If Young was arrested on the Manatee County warrant in Palm Beach County (as opposed to held on a detainer), he is entitled to credit for time spent there.
[1] A trial court must attach record evidence conclusively showing a defendant is entitled to no relief when summarily denying a motion for additional jail credit.
[2] An appellate court must reverse an order summarily denying a motion for additional jail credit if the record fails to conclusively refute the defendant's claim for relief…
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Join FLexlaw to unlock all legal intelligence“Nothing in the record indicates that the time Young spent in the Palm Beach County jail was calculated into the amount of jail credit awarded, and the trial court fails to address this claim for jail credit in its order denying relief.”
Establishes that the trial court's order was deficient for not addressing the Palm Beach County jail time claim
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceYoung was sentenced in 1993 to 5.5 years in prison with 144 days of jail credit. In 2001, he was arrested on a probation violation warrant from Manate…
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FULMER, Judge.
Steven T. Young appeals the denial of his motion for jail credit filed pursuant to Florida Rule of Criminal Procedure 3.800(a). We reverse and remand because the record provided by the trial court does not refute Young’s claim that he is entitled to additional jail credit.
On July 23, 1993, the trial court sentenced Young to 5.5 years in prison followed by three years’ probation on one count in Manatee County case number 93-503 and one count in Manatee County case number 93-504. The trial court ordered the sentences to run concurrent with each other and awarded Young 144 days of jail credit in both cases. In 2001, Young was arrested for violating his probation, and the trial court sentenced him to seven years in prison with credit for 247 days in both cases.
In his motion, Young claims that he was arrested in Palm Beach County on October 4, 2001, on the violation of probation warrant from Manatee County and held in the Palm Beach County jail until December 21, 2001. Young claims that he was held in the Manatee County jail from December 21, 2001, until April 2, 2002, when he was sentenced on the violation of probation charges. He claims that he is entitled to additional jail credit for the time he spent in the Palm Beach County jail. The trial court denied this claim, stating that because Young had already been awarded 247 days of jail credit, he was not entitled to additional jail credit. The trial court did not explain its calculation. However, we observe that the dates Young alleges he was held in the Manatee County jail total 103 days which, if added to the original 144 days of jail credit, equals 247 days.
Nothing in the record indicates that the time Young spent in the Palm Beach County jail was calculated into the amount of jail credit awarded, and the trial court fails to address this claim for jail credit in its order denying relief. Therefore, we reverse and remand for the trial court to consider whether Young is entitled to credit for the days he was held in the Palm Beach County jail. If Young was arrested on the Manatee County warrant in Palm Beach County, as opposed to being held on a detainer, he is entitled to credit for the time he spent in the Palm Beach County jail. See Gethers v. State, 838 So. 2d 504 (Fla.2003). If the trial court denies Young’s claim, it must attach portions of the record which demonstrate that he is not entitled to jail credit for the time he spent in the Palm Beach County jail.
Reversed and remanded.
DAVIS and CANADY, JJ., concur.
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Thomas v. State, 863 So. 2d 1277 (Fla. 2d DCA 2004)…of probation on a Hillsborough County warrant. If Thomas was arrested in Pi-nellas County at least partially on a Hills-borough County warrant, she is entitled to credit for the sixty-three days spent in the Pinellas County jail. See Young v. State, 840 So. 2d 468 (Fla. 2d DCA 2003); LeBlanc v. State, 839 So. 2d 896 (Fla. 3d DCA 2003). Nothing in the record clearly refutes Thomas’ claim that she was entitled to sixty-three days’ jail credit for the time she spent in the Pinellas County jail from May 2, 2002,…
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Cousnard v. State, 188 So. 3d 936 (Fla. 1st DCA 2016)…wever, it appears this award of jail credit did not include all twelve (12) days’ credit awarded Appellant on November 4, 2013, when he was originally placed on probation. See Gammon v. State, 738 So. 2d 980, 981 (Fla. 1st DCA 1999); Young v. State, 840 So. 2d 468, 468 (Fla. 2d DCA 2003). Therefore, we reverse the denial of Appellant’s Rule 3.800(b)(2) motion, and remand to the trial court to recalculate Appellant’s credit for time served and re-sentence him as appropriate. AFFIRMED in part; REVERSED in part…
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Harnage v. State, 946 So. 2d 598 (Fla. 4th DCA 2006)…om the date the Martin County violation of probation warrant was formally executed. Gethers v. State, 798 So. 2d 829 (Fla. 4th DCA 2001), approved by, 838 So. 2d 504 (Fla.2003); Martinez v. State, 940 So. 2d 1277 (Fla. 4th DCA 2006); Young v. State, 840 So. 2d 468 (Fla. 2d DCA 2003). Harnage failed to identify record evidence to support a claim that he was held solely on the Martin County detainer while jailed in St. Lucie County. Bonilla v. State, 884 So. 2d 1072 (Fla. 5th DCA 2004). Under the circumstances…
Authorities Cited
- Gethers v. State, 838 So. 2d 504 (Fla. 2003)