Christopher Nelson v. State of Florida

The appellant filed a motion pursuant to Florida Rule of Criminal Procedure 3.801 seeking additional jail credit. For the reasons discussed below, we reverse and remand.

The appellant alleged an entitlement to 52 additional days of credit for time spent in the “ART Program” as a condition of his probation. Specifically, he asserts that the trial court orally pronounced that he was to be given credit for all time he spent in the ART program. The trial court ruled that the appellant was actually awarded more credit that he was entitled to receive, and that he was not entitled to credit for the…