JAMIE MEADE, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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Jamie Meade appealed the trial court's summary denial of her rule 3.800(a) motion seeking additional jail credit for her Sumter County organized fraud sentence. The court affirmed the denial of 77 days of credit for time served under a detainer while incarcerated on unrelated charges, but reversed and remanded regarding four days of credit for time awaiting sentencing in Sumter County, finding the trial court failed to attach record evidence supporting its denial.
Meade is not entitled to 77 additional days of credit for time served on unrelated St. Johns County charges while the Sumter County detainer was in place. However, the trial court's summary denial of the four-day credit claim must be reversed and remanded because the trial court failed to attach record evidence supporting its denial and the 42 days of original credit did not appear to include time spent awaiting sentencing in Sumter County in August.
[1] A detainer lodged by one county against a defendant incarcerated in another county does not entitle the defendant to jail credit from the detaining county for the time se…
[2] A trial court must attach record attachments to refute a defendant's claim for jail credit in a rule 3.800(a) motion.
Previewing 2 of 5 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“When a county issues a detainer or hold to another county, it is merely requesting either to hold the defendant for the second county or to notify the second county when release is imminent so that the second county can act. In that case, no jail credit need be awarded by the second county for time served in the first county for the period during which the detainer or hold is lodged.”
Establishes the legal principle that time served under a detainer in another county is not creditable to the sentencing county.
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Join FLexlaw to unlock all legal intelligenceMeade was arrested on March 12, 2004 for a Sumter County organized fraud offense and released on her own recognizance on April 22, 2004. While awaitin…
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Jamie Meade appeals the trial court’s summary denial of her rule 3.800(a) motion in which she asserts entitlement to more days of jail credit than the trial court awarded her at sentencing on her Sumter County offense of organized fraud. We affirm in part, reverse in part, and remand.
Specifically, Meade’s rule 3.800(a) motion alleges that she was arrested on March 12, 2004, for the Sumter County offense and was released on her own recognizance on April 22, 2004, pending sentencing at a later date.1 While on release, Meade answered to, and was sentenced for, unrelated St. Johns County offenses and was placed in the custody of the Department of Corrections, which housed her at the Lowell Correctional Institution. Sumter County issued a detainer against Meade while she was incarcerated at Lowell. After issuance of the detainer, Meade continued to serve her St. Johns County sentence for another 77 days before being transported to Sumter County for sentencing. According to Meade, four days after her arrival in Sumter County, sentencing on the Sumter County offense took place.2 That sentence included an award of 42 days of jail credit — a figure Meade contends fails to credit her with all the time due her.
Meade argues that she is entitled to additional jail credit of 77 days for the period of time (May 23, 2004, through August 7, 2004) Sumter County’s detainer was in place against her while she was incarcerated at Lowell on the St. Johns County offenses. Meade further argues she is entitled to additional jail credit of four days for the time she served while *1084awaiting sentencing in Sumter County after she was transported from Lowell. She alleges that this period ran from August 7, 2004, the last day of the detainer, to August 11, 2004, when she was sentenced in Sumter County.
Meade is not entitled to an additional 77 days of credit for the time she served in prison on the unrelated charges from St. Johns County by virtue of the Sumter County detainer. See Gethers v. State, 838 So.2d 504, 508 (Fla.2003) (“When a county issues a detainer or hold to another county, it is merely requesting either to hold the defendant for the second county or to notify the second county when release is imminent so that the second county can act. In that case, no jail credit need be awarded by the second county for time served in the first county for the period during which the detainer or hold is lodged.”).
With respect to the remaining four days she claims, however, we are compelled to reverse and remand because the trial court failed to refute her claim with record attachments to its order. It appears that the trial court denied relief with regard to the four days on the basis that the 42-day credit already included jail credit for the days Meade spent in Sumter County awaiting sentencing. However, if Meade’s version of the pertinent dates is correct, the 42 days credited her included only the time served from her arrest date of March 12, 2004, to her release on her own recognizance on April 22, 2004. It would not include the additional time she served in August while awaiting sentencing on the Sumter County offense after being transported from Lowell to Sumter County.
The trial court summaiily denied Meade’s claim finding that “Defendant has been already awarded jail time credit for the period of time spent in the Sumter County jail awaiting sentencing.” The problem is that the trial court failed to attach portions of the record refuting the claim. Thus, it is necessary to reverse and remand for the purpose of allowing the court to either attach sufficient portions of the record refuting the claim, grant credit for four additional days of jail time or, if the issue cannot be determined based on the face of the record, deny the claim without prejudice to Meade to file a timely motion pursuant to rule 3.850, Florida Rules of Criminal Procedure, if she is able to do so.
AFFIRMED in part; REVERSED in part; REMANDED for record attachments.
SAWAYA, ORFINGER and TORPY, JJ., concur.