EDWIN BERNARD RATTRAY
v.
STATE OF FLORIDA

Fla. 1st DCA | 2026-07-08
No. 2025-3030
Colaw, J., Kelsey, J., Nordby, J., Neff, J.
2026 FL 8422 Florida District Court of Appeal, First District (2026)

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Holding

Rule 3.801 is the exclusive remedy for jail credit issues, and procedural case law on jail credit preceding the rule's enactment is irrelevant.


Headnotes

[1] Florida Rule of Criminal Procedure 3.801 provides the exclusive remedy for jail credit issues, and procedural case law on jail credit predating the rule's enactment is in…

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Key Quotes

“rule 3.801 is the exclusive remedy for jail credit issues and 'procedural case law on jail credit preceding rule 3.801's enactment is irrelevant'”

Court's citation to Murray v. State in support of affirmance

Facts & Procedural History

Edwin Bernard Rattray appealed a decision from the Circuit Court for Alachua County regarding jail credit.…

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Topics

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Opinion of the Court

FIRST DISTRICT COURT OF APPEAL

STATE OF FLORIDA

No. 1D2025-3030

EDWIN BERNARD RATTRAY, Appellant,

v.

STATE OF FLORIDA, Appellee.

On appeal from the Circuit Court for Alachua County. James Matthew Colaw, Judge.

July 8, 2026

PER CURIAM.

AFFIRMED. See Murray v. State, 397 So. 3d 223, 225 (Fla. 6th DCA 2024) (holding that rule 3.801 is the exclusive remedy for jail credit issues and “procedural case law on jail credit preceding rule 3.801's enactment is irrelevant”); Fla. R. Crim. P. 3.801(b).

KELSEY, NORDBY, and NEFF, JJ., concur.


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