Bonckowski v. State

Mr. Bonckowski did not allege that any error in jail credit can be ascertained from the face of the record. He did not, therefore, present a facially sufficient jail credit claim pursuant to Florida Rule of Criminal Procedure 3.800(a). See Cabrera v. State, 62 So.3d 1171, 1172 (Fla. 4th DCA 2011). A motion pursuant to Florida Rule of Criminal Procedure 3.850 would, however, presumably still be timely. See Dennis v. State, 9 So.3d 761 (Fla. 1st DCA 2009).