Brown v. State

The postconviction court’s denial of Antonio D. Brown’s motion filed under Florida Rule of Criminal Procedure 3.800(a) is affirmed without prejudice for Brown to file a motion under rule 3.801. If Brown chooses to file a rule 3.801 motion, it must comply with the requirements outlined in *826rules 3.801(b), (c), (e), and 3.850(n). Upon receipt of a rule 3.801 motion, the court must follow the procedure outlined in rule 3.850(f). See Fla. R.Crim. P. 3.801(e) (effective July 1, 2013).

In its order, the postconviction court did not indicate whether Brown is entitled to credit for time spent in jail…