Crandall v. State
The Fifth DCA reversed the summary denial of a pro se rule 3.800(a) motion to correct illegal sentence, holding it should instead have been stricken as a nullity because it was both filed prematurely (during the 30-day window when only a 3.800(b)(1) motion could be filed) and while the defendant was still represented by appointed counsel without an unequivocal request to discharge counsel. The court remanded with directions to strike the motion, without prejudice to Crandall refiling a proper motion after his direct appeal becomes final.
Key facts
- Crandall filed a pro se rule 3.800(a) motion to correct an allegedly illegal sentence during the 30-day period following sentencing, while still represented by appointed counsel, without requesting to discharge that counsel.
- The trial court summarily denied Crandall's motion on the merits without addressing procedural defects in its filing.
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Why it matters
This opinion clarifies the interplay between rules 3.800(a) and 3.800(b) regarding timing, confirming that a 3.800(a) motion is barred during the 30-day appeal window reserved for 3.800(b)(1) motions. It also reinforces… — full analysis with a trial
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