Murray v. State
Murray sought additional jail credit via a Florida Rule of Criminal Procedure 3.800(a) motion, arguing his written sentence omitted credit for time between vacatur of his first sentence and imposition of his second. The Sixth DCA held the trial court's reasoning for denying relief was wrong but affirmed under the tipsy coachman doctrine because rule 3.801, not rule 3.800(a), is the exclusive vehicle for jail-credit claims, and Murray's claim was time-barred since he failed to file within the one-year grace period after rule 3.801's 2013 enactment.
Key facts
- Murray sought additional jail credit via a Rule of Criminal Procedure 3.800(a) motion, claiming his written sentence omitted credit for time between vacatur of his first sentence and imposition of his second sentence.
- The trial court denied Murray's motion, but the Sixth District Court of Appeal found the trial court's reasoning was incorrect.
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Why it matters
This opinion is useful to practitioners handling jail-credit disputes because it reaffirms and applies the sometimes-overlooked rule that 3.801, not 3.800(a), is the exclusive avenue for correcting jail credit errors… — full analysis with a trial
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