Lane v. State
Lane, serving a new prison sentence after his probation was revoked, sought correction of jail credit under Rule 3.801, actually seeking to retain 150 days of DOC-awarded prison gain time that had been forfeited upon revocation. The Third DCA affirmed denial of the motion, holding that gain time is not 'time served' within the meaning of Rule 3.801 and section 921.161, and that the authority to forfeit accrued prison gain time upon probation revocation rests exclusively with the Florida Department of Corrections under section 944.28(1) and section 948.06(7), regardless of any 'recommendation' language in the trial court's sentencing order.
Key facts
- Lane, serving a new prison sentence after probation revocation, moved under Rule 3.801 to correct jail credit and retain 150 days of prison gain time that the Department of Corrections had forfeited upon revocation.
- The trial court denied the motion, and Lane appealed to the Third District Court of Appeal.
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Why it matters
This opinion clarifies the narrow scope of Rule 3.801 jail-credit motions and reaffirms that DOC—not the sentencing court—has exclusive statutory authority to forfeit accrued prison gain time when probation is revoked… — full analysis with a trial
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