Michael Darrin Zill v. State

Michael Zill appeals the denial of a rule 3.800(a) motion to correct an illegal sentence. His motion raised two claims: an error in his credit for time served and a discrepancy between the written sentence and the oral pronouncement.

Zill’s rule 3.800(a) motion was filed after the effective date of rule 3.801, which applies to correction of jail credit. His motion was not under oath and did not include the content required by rule 3.801(c). The time for him to file a rule 3.801 motion expired on July 1, 2014. We affirm the denial of this portion of the order.

In his second claim Zill alleged…