Robinson v. State
A divided Fifth District panel held that FDLE agents' takedown of Robinson in Suwannee County pursuant to a Duval County arrest warrant constituted an 'arrest' under the Melton four-factor test, triggering Florida's speedy trial clock even though Robinson was ultimately booked and prosecuted only on unrelated local drug/firearm charges discovered incident to that takedown. Because the State did not formally charge the Duval County attempted murder offense until nearly two years later, the majority held Robinson was entitled to discharge under Rule 3.191, while Judge Boatwright dissented in part, arguing the Melton factors (intent and communication) were not established by competent evidence. All three judges joined in certifying a question asking the Florida Supreme Court to reconsider State v. Williams' holding that the speedy trial recapture period is unavailable once the 175-day period expires without charges being filed.
Key facts
- FDLE agents executed an outstanding Duval County arrest warrant for attempted murder against Robinson in Suwannee County, taking him into custody.
- Incident to the warrant takedown, agents discovered drugs and firearms, leading Robinson to be booked and prosecuted on those unrelated local charges rather than the Duval County attempted murder charge.
- +2 more key facts with a free trial
Why it matters
This opinion is significant because it certifies a question of great public importance asking the Florida Supreme Court to revisit or abandon the 20-year-old rule in State v. Williams requiring automatic discharge… — full analysis with a trial
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