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Willis v. State

District Court of Appeal of Florida, Fifth District
Oct 2, 2009
18 So. 3d 1215 (Fla. Dist. Ct. App. 2009)

Summary

holding that credit for time spent in jail after sentencing must be addressed to the Department of Corrections

Summary of this case from Brown v. State

Opinion

No. 5D09-2369.

October 2, 2009.

Appeal from the Circuit Court, Marion County, David B. Eddy, J.

Robert Willis, DeFuniak Springs, pro se.

No Appearance for Appellee.


Robert Willis appeals an order denying. his motion seeking additional jail credit, filed pursuant to Florida Rule of Criminal Procedure 3.800(a). The trial judge correctly denied the motion, finding that Willis had been credited with all of the time he spent in the county jail on his charges prior to sentencing. See § 921.161(1), Fla. Stat. (2008). Willis' motion requested that the court grant additional jail credit for the time he spent in jail after sentencing, awaiting transport to the Department of Corrections. This request should have been made to the Department itself. See § 921.161(2), Fla. Stat. (2008); see also Smith v. State, 932 So.2d 594, 595 (Fla. 5th DCA 2006) (a "trial court is only required to award credit for presentence jail time; it is the function of the Department of Corrections to award credit for any time served in jail after sentencing but before transfer to state prison"); Leiffer v. State, 867 So.2d 538, 538 n. 1 (Fla. 5th DCA 2004) ("For issues involving post-sentencing credit, a defendant must first exhaust his administrative remedies and then seek mandamus relief. . . .").

AFFIRMED.

PALMER and JACOBUS, JJ., concur.


Summaries of

Willis v. State

District Court of Appeal of Florida, Fifth District
Oct 2, 2009
18 So. 3d 1215 (Fla. Dist. Ct. App. 2009)

holding that credit for time spent in jail after sentencing must be addressed to the Department of Corrections

Summary of this case from Brown v. State

affirming the trial court's order denying Willis's motion for additional jail credit for time spent in jail after sentencing and holding that Willis's motion should have been directed to the DOC

Summary of this case from Valdespino v. State
Case details for

Willis v. State

Case Details

Full title:Robert WILLIS, Appellant, v. STATE of Florida, Appellee

Court:District Court of Appeal of Florida, Fifth District

Date published: Oct 2, 2009

Citations

18 So. 3d 1215 (Fla. Dist. Ct. App. 2009)

Citing Cases

Valdespino v. State

The award of post-sentencing jail time is the function of the DOC. See Willis v. State , 18 So.3d 1215 (Fla.…

Brown v. State

Affirmed. See Reasee v. State, 123 So.3d 693 (Fla. 4th DCA 2013) ; see also Willis v. State, 18 So.3d 1215…